Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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