Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
The dominant issue was whether the percentage completion method under s. 43CB applies to real-estate business for estimating business profit, thereby sustaining additions toward estimated business income and deemed rental income. The appellate authority held that s. 43CB mandatorily applies to real-estate projects and, following binding precedent, rejected the taxpayer's contention that the provision was inapplicable; consequently, the additions made under s. 43CB were confirmed. As no material was produced to rebut these findings, the tribunal declined to interfere and dismissed the appeal. - ITAT
The dominant issue was whether the percentage completion method under s. 43CB applies to real-estate business for estimating business profit, thereby sustaining additions toward estimated business income and deemed rental income. The appellate authority held that s. 43CB mandatorily applies to real-estate projects and, following binding precedent, rejected the taxpayer's contention that the provision was inapplicable; consequently, the additions made under s. 43CB were confirmed. As no material was produced to rebut these findings, the tribunal declined to interfere and dismissed the appeal. - ITAT
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