Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Reassessment proceedings under section 147 are confined to bringing escaped or under-assessed income to tax and cannot be used by an assessee to reopen a concluded matter or withdraw income voluntarily offered in the original return. Where the income had been disclosed under section 139(1), a return filed in response to section 148 could not be used to reduce assessed house property income or obtain review of the original position. The addition was sustained, the merits of the ownership-based explanation were left open as academic, and the appellate order was upheld.
Reassessment proceedings under section 147 are confined to bringing escaped or under-assessed income to tax and cannot be used by an assessee to reopen a concluded matter or withdraw income voluntarily offered in the original return. Where the income had been disclosed under section 139(1), a return filed in response to section 148 could not be used to reduce assessed house property income or obtain review of the original position. The addition was sustained, the merits of the ownership-based explanation were left open as academic, and the appellate order was upheld.
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