Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Validity of Reopening of assessment - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
Validity of Reopening of assessment - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
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