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...
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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