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...
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
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