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Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
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