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...
HC held that the specified authority for approval under Section 151 depends on whether the reassessment notice under Section 148 was issued within three years from the end of the relevant assessment year. The court consistently interpreted that the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) extension does not impact the determination of the mandatory approval authority. Based on this legal principle, the court set aside the impugned notice, thereby allowing the assessee's appeal and invalidating the reassessment proceedings due to procedural non-compliance with Section 151 approval requirements.
HC held that the specified authority for approval under Section 151 depends on whether the reassessment notice under Section 148 was issued within three years from the end of the relevant assessment year. The court consistently interpreted that the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) extension does not impact the determination of the mandatory approval authority. Based on this legal principle, the court set aside the impugned notice, thereby allowing the assessee's appeal and invalidating the reassessment proceedings due to procedural non-compliance with Section 151 approval requirements.
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