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...
Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.
Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.
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