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Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
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Faceless reassessment under section 147 read with section 144B was treated as a best judgment reassessment where the assessee did not comply with section 142(1) notices and did not properly respond to section 144 show-cause notices. On that footing, the proviso to section 251(1)(a), effective from 01.10.2024, permitted the appellate authority to set aside the assessment and remand it for fresh adjudication. The remand was upheld because the assessing officer had not verified the material and additional evidence had been filed in appeal, making de novo assessment with opportunity to the assessee justified. The Revenue's objection was rejected and the reassessment was sent back for fresh disposal.
Faceless reassessment under section 147 read with section 144B was treated as a best judgment reassessment where the assessee did not comply with section 142(1) notices and did not properly respond to section 144 show-cause notices. On that footing, the proviso to section 251(1)(a), effective from 01.10.2024, permitted the appellate authority to set aside the assessment and remand it for fresh adjudication. The remand was upheld because the assessing officer had not verified the material and additional evidence had been filed in appeal, making de novo assessment with opportunity to the assessee justified. The Revenue's objection was rejected and the reassessment was sent back for fresh disposal.
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