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Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Transfer pricing disputes over intra-group services, the sensor assembling segment and business support services were restored for fresh adjudication because the assessee sought to place additional evidence and the Tribunal found reconsideration necessary. The intra-group services adjustment was remitted to the AO/TPO for fresh decision after due opportunity. The choice between the Resale Price Method and the Transactional Net Margin Method for the sensor assembling segment was left open for reconsideration, and the comparables, filter changes and denied risk adjustment in business support services were also remitted. The assessment order was set aside to that extent and the appeal was partly allowed for statistical purposes.
Transfer pricing disputes over intra-group services, the sensor assembling segment and business support services were restored for fresh adjudication because the assessee sought to place additional evidence and the Tribunal found reconsideration necessary. The intra-group services adjustment was remitted to the AO/TPO for fresh decision after due opportunity. The choice between the Resale Price Method and the Transactional Net Margin Method for the sensor assembling segment was left open for reconsideration, and the comparables, filter changes and denied risk adjustment in business support services were also remitted. The assessment order was set aside to that extent and the appeal was partly allowed for statistical purposes.
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