Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Validity of reopening u/s 147 r.w.s. 148 - The Tribunal found that the reasons recorded by the Assessing Officer (AO) for reopening the assessment under section 147/148 were based on incorrect assumptions and information. Specifically, the AO erroneously believed that the assessee, an individual, had entered into a transaction of sale of immovable property, whereas the transaction was actually between two partnership firms. - The Tribunal noted that the AO should have issued a notice to the partnership firm involved instead of the individual assessee. - Consequently, entire proceedings u/s. 148 is held to be invalid.
Validity of reopening u/s 147 r.w.s. 148 - The Tribunal found that the reasons recorded by the Assessing Officer (AO) for reopening the assessment under section 147/148 were based on incorrect assumptions and information. Specifically, the AO erroneously believed that the assessee, an individual, had entered into a transaction of sale of immovable property, whereas the transaction was actually between two partnership firms. - The Tribunal noted that the AO should have issued a notice to the partnership firm involved instead of the individual assessee. - Consequently, entire proceedings u/s. 148 is held to be invalid.
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