Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT held that the reassessment proceedings initiated under s.147 and notice issued under s.148 are invalid because the Pr. CIT's approval under s.151(2) was a mechanical, non-application of mind endorsement. Relying on controlling High Court precedent that condemns perfunctory sanctions evidenced by mere recorded satisfaction, the Tribunal found the sanction to reopen was vitiated. Consequentially, the s.148 notice was held bad in law and the consequent reassessment order was quashed. The appeal by the assessee was allowed and the reassessment proceedings set aside.
ITAT held that the reassessment proceedings initiated under s.147 and notice issued under s.148 are invalid because the Pr. CIT's approval under s.151(2) was a mechanical, non-application of mind endorsement. Relying on controlling High Court precedent that condemns perfunctory sanctions evidenced by mere recorded satisfaction, the Tribunal found the sanction to reopen was vitiated. Consequentially, the s.148 notice was held bad in law and the consequent reassessment order was quashed. The appeal by the assessee was allowed and the reassessment proceedings set aside.
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