Reopening of assessment u/s 147 - Transfer Pricing Reference u/s...

Reopening of assessment u/s 147 - Transfer Pricing Reference u/s 92CA - Revenue does not dispute that both the source of income and the subject investment are mentioned in the books of accounts, and the Revenue also does not contend that the petitioner did not have the necessary resources to make such investment. Importantly, the Revenue does not contend that the payment of premium by the petitioner to MMG's shareholders for purchase of the shares will not be reflected in the MMG's financials. The petitioner's objections in this regard are rejected only on the ground that the explanation could be considered at the time of reassessment. - Both the notice and order quashed - HC