Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The ITAT allowed the appeal of Assessee X, holding the reassessment proceedings under s.147 invalid due to improper sanction under the new s.151 regime. The notice u/s 148 and order u/s 148A(d), issued beyond three years from the relevant assessment year, required prior approval from higher specified authorities (PCCI/PDGIT/CCIT/DGIT), but were instead sanctioned by the PCIT, contrary to the amended statutory hierarchy. Relying on binding precedents of the SC and the jurisdictional HC, and holding that TOLA only extended limitation and did not alter the approval structure under s.151, the ITAT quashed the notice u/s 148 and consequently annulled the reassessment order. The assessee's appeal was allowed in full.
The ITAT allowed the appeal of Assessee X, holding the reassessment proceedings under s.147 invalid due to improper sanction under the new s.151 regime. The notice u/s 148 and order u/s 148A(d), issued beyond three years from the relevant assessment year, required prior approval from higher specified authorities (PCCI/PDGIT/CCIT/DGIT), but were instead sanctioned by the PCIT, contrary to the amended statutory hierarchy. Relying on binding precedents of the SC and the jurisdictional HC, and holding that TOLA only extended limitation and did not alter the approval structure under s.151, the ITAT quashed the notice u/s 148 and consequently annulled the reassessment order. The assessee's appeal was allowed in full.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
