Tag Archives: Dy. CIT

Reassessment Order Based on Mechanical Sanction Under Section 151 Lacking Year-Wise Investment Examination Is Invalid

By | November 5, 2026
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Reassessment Order Based on Mechanical Sanction Under Section 151 Lacking Year-Wise Investment Examination Is Invalid Issue Whether a reassessment initiated under Section 147 is legally sustainable when the approval under Section 151 suffers from non-application of mind regarding year-wise property payments, and whether Section 292BC can retrospectively validate an invalid Section 151 approval obtained prior… Read More »

Ad Hoc Tenure Filters for Transfer Pricing and Section 94B Recomputation Are Unjustified

By | September 26, 2026
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Ad Hoc Tenure Filters for Transfer Pricing and Section 94B Recomputation Are Unjustified Issue Whether the Transfer Pricing Officer (TPO) can introduce an ad hoc minimum tenure filter of 10 years into an external CUP study without economic justification to alter the arm’s-length interest rate on Non-Convertible Debentures (NCDs). Whether additional disallowance under Section 94B… Read More »