Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
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