Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ITAT held that the Assessing Officer's combined satisfaction note under section 153C for multiple assessment years was invalid, as per the requirement to record separate satisfaction notes for each year, rendering the assessment proceedings vitiated. Furthermore, the approval granted under section 153D was found to be mechanical and without proper application of mind, which is legally impermissible. Consequently, the approvals under section 153D were held to be non-compliant with statutory mandates, leading to the quashing of the related assessment orders. The appeal was allowed, resulting in the annulment of the assessments based on defective satisfaction and approval notes.
The ITAT held that the Assessing Officer's combined satisfaction note under section 153C for multiple assessment years was invalid, as per the requirement to record separate satisfaction notes for each year, rendering the assessment proceedings vitiated. Furthermore, the approval granted under section 153D was found to be mechanical and without proper application of mind, which is legally impermissible. Consequently, the approvals under section 153D were held to be non-compliant with statutory mandates, leading to the quashing of the related assessment orders. The appeal was allowed, resulting in the annulment of the assessments based on defective satisfaction and approval notes.
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