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...
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
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