Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
ITAT held the assessment u/s 153A invalid due to procedural defects in approval u/s 153D. The tribunal found the approval was granted mechanically without proper application of mind, as the approving authority lacked access to relevant assessment records and seized materials. Consequently, the assessment order dated 15.03.2016 was quashed as legally unsustainable. The appellate authority set aside the lower court's orders, effectively allowing the assessee's appeal and invalidating the assessment proceedings based on fundamental procedural irregularities in the approval process.
ITAT held the assessment u/s 153A invalid due to procedural defects in approval u/s 153D. The tribunal found the approval was granted mechanically without proper application of mind, as the approving authority lacked access to relevant assessment records and seized materials. Consequently, the assessment order dated 15.03.2016 was quashed as legally unsustainable. The appellate authority set aside the lower court's orders, effectively allowing the assessee's appeal and invalidating the assessment proceedings based on fundamental procedural irregularities in the approval process.
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