Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Issuance of a reassessment notice under the new regime required compliance with the sanction structure in section 151, and where more than three years had elapsed from the end of the relevant assessment year, prior approval had to be obtained from the Principal Chief Commissioner or equivalent authority under section 151(ii). Because the notice for AY 2016-17 was approved by the Pr. CIT instead of the specified authority, the approval was held jurisdictionally defective. The Tribunal treated proper sanction as a mandatory pre-condition, quashed the section 148 notice, and held that the consequential reassessment under section 147 could not survive; the merits were left academic.
Issuance of a reassessment notice under the new regime required compliance with the sanction structure in section 151, and where more than three years had elapsed from the end of the relevant assessment year, prior approval had to be obtained from the Principal Chief Commissioner or equivalent authority under section 151(ii). Because the notice for AY 2016-17 was approved by the Pr. CIT instead of the specified authority, the approval was held jurisdictionally defective. The Tribunal treated proper sanction as a mandatory pre-condition, quashed the section 148 notice, and held that the consequential reassessment under section 147 could not survive; the merits were left academic.
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