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...
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
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