Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
