Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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ITAT upheld the reassessment notice because the record showed prior approval of the Principal Commissioner on the notice under section 148A(b), and both the notice and approval were within the statutory time limit, so the challenge on limitation and lack of approval failed. On disputed bogus purchases, the Tribunal held that invoices, ledgers and banking entries were not enough where Investigation Wing and GST material indicated accommodation entry suppliers and there were deficiencies in transport and purchase-to-sale linkage. It found that the existing factual examination was inadequate to sustain either full disallowance or a restriction to 15%, and restored the matter to the Assessing Officer for fresh verification and enquiries.
ITAT upheld the reassessment notice because the record showed prior approval of the Principal Commissioner on the notice under section 148A(b), and both the notice and approval were within the statutory time limit, so the challenge on limitation and lack of approval failed. On disputed bogus purchases, the Tribunal held that invoices, ledgers and banking entries were not enough where Investigation Wing and GST material indicated accommodation entry suppliers and there were deficiencies in transport and purchase-to-sale linkage. It found that the existing factual examination was inadequate to sustain either full disallowance or a restriction to 15%, and restored the matter to the Assessing Officer for fresh verification and enquiries.
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