Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Parallel reassessment proceedings under sections 147/148 did not invalidate validly initiated section 153C proceedings, because the Tribunal found no legal basis to quash section 153C merely due to non-dropping of reassessment action. However, satisfaction for invoking section 153C must be recorded without inordinate delay, and recording it nearly four years after the search was held unjustified. On that ground, the Tribunal quashed the section 153C proceedings for both assessment years, applying the same delay finding where the search date and notice date were identical.
Parallel reassessment proceedings under sections 147/148 did not invalidate validly initiated section 153C proceedings, because the Tribunal found no legal basis to quash section 153C merely due to non-dropping of reassessment action. However, satisfaction for invoking section 153C must be recorded without inordinate delay, and recording it nearly four years after the search was held unjustified. On that ground, the Tribunal quashed the section 153C proceedings for both assessment years, applying the same delay finding where the search date and notice date were identical.
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