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...
Belated filing of Form 10-IC was treated as a procedural lapse where the assessee had clearly opted for the concessional regime under section 115BAA by computing tax accordingly in the return and the form was on record when the return was processed. As the form had not been withdrawn, rejected or invalidated, and eligibility for the lower rate was undisputed, the delay did not justify denial of the statutory benefit. Tax was directed to be recomputed at the concessional rate under section 115BAA.
Belated filing of Form 10-IC was treated as a procedural lapse where the assessee had clearly opted for the concessional regime under section 115BAA by computing tax accordingly in the return and the form was on record when the return was processed. As the form had not been withdrawn, rejected or invalidated, and eligibility for the lower rate was undisputed, the delay did not justify denial of the statutory benefit. Tax was directed to be recomputed at the concessional rate under section 115BAA.
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