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...
Prior approval for search assessments was treated as a substantive jurisdictional safeguard, so the approving authority had to apply an independent mind to the appraisal report, seized material and assessment records for each year. The ITAT majority found that the Addl. CIT relied only on what the Assessing Officer stated, issued identically worded approvals for multiple years, and did not demonstrate any real examination of the relevant material. Such mechanical and non-speaking approval could not substitute the statutory requirement, and the assessments based on it were held unsustainable and quashed.
Prior approval for search assessments was treated as a substantive jurisdictional safeguard, so the approving authority had to apply an independent mind to the appraisal report, seized material and assessment records for each year. The ITAT majority found that the Addl. CIT relied only on what the Assessing Officer stated, issued identically worded approvals for multiple years, and did not demonstrate any real examination of the relevant material. Such mechanical and non-speaking approval could not substitute the statutory requirement, and the assessments based on it were held unsustainable and quashed.
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