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...
A related-party slump sale capital loss was disallowed because the assessee failed to prove genuineness, valuation basis and fair consideration through independent material, and the claimed loss was not supported beyond book entries. Compensation received on the departure of a key medical professional was taxed as revenue receipt because the hospital's profit-earning apparatus remained intact and the payment was linked to anticipated business loss rather than destruction of a capital source. The Tribunal also upheld deletion of interest disallowance and interest capitalisation additions on the footing that the assessee had sufficient own funds. Section 14A was held inapplicable because no exempt income was earned during the year.
A related-party slump sale capital loss was disallowed because the assessee failed to prove genuineness, valuation basis and fair consideration through independent material, and the claimed loss was not supported beyond book entries. Compensation received on the departure of a key medical professional was taxed as revenue receipt because the hospital's profit-earning apparatus remained intact and the payment was linked to anticipated business loss rather than destruction of a capital source. The Tribunal also upheld deletion of interest disallowance and interest capitalisation additions on the footing that the assessee had sufficient own funds. Section 14A was held inapplicable because no exempt income was earned during the year.
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