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...
Jurisdiction for notice under section 148 was tested on the material available when proceedings began, not on the income ultimately assessed. The Tribunal held that section 149(1)(b) permitted notice beyond three years where the Assessing Officer possessed books, documents or evidence indicating income represented in the form of an asset and likely to meet the statutory threshold. Cash withdrawals exceeding Rs. 1.50 crores, together with non-filing of a return, constituted tangible material for a prima facie view that the threshold was satisfied. The assessee's time-bar objection failed, and the reassessment notice was upheld as valid.
Jurisdiction for notice under section 148 was tested on the material available when proceedings began, not on the income ultimately assessed. The Tribunal held that section 149(1)(b) permitted notice beyond three years where the Assessing Officer possessed books, documents or evidence indicating income represented in the form of an asset and likely to meet the statutory threshold. Cash withdrawals exceeding Rs. 1.50 crores, together with non-filing of a return, constituted tangible material for a prima facie view that the threshold was satisfied. The assessee's time-bar objection failed, and the reassessment notice was upheld as valid.
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