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 assessments by issuing a notice for reassessment beyond three years is invalid where the statutory conditions for extended reassessment and required sanction/approval were not satisfied; such notices are void ab initio and the consequent assessment orders are liable to be quashed. Where initial reassessment proceedings were dropped, issuing a fresh reassessment notice without first following the mandated pre-reopening consultation and disposal procedure is contrary to the reassessment scheme and therefore invalid; a second notice issued on the same recorded reasons without complying with that procedure is quashed along with resulting assessment orders.
Reopening assessments by issuing a notice for reassessment beyond three years is invalid where the statutory conditions for extended reassessment and required sanction/approval were not satisfied; such notices are void ab initio and the consequent assessment orders are liable to be quashed. Where initial reassessment proceedings were dropped, issuing a fresh reassessment notice without first following the mandated pre-reopening consultation and disposal procedure is contrary to the reassessment scheme and therefore invalid; a second notice issued on the same recorded reasons without complying with that procedure is quashed along with resulting assessment orders.
Note: It is a system-generated summary and is for quick reference only.
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