Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
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