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 notices issued under s.153C were valid in view of s.153C(3) for searches initiated on or after 01.04.2021. The Tribunal held that the date on which seized material is handed over to the assessee's jurisdictional AO constitutes the "date of initiation of search" for purposes of s.153C(3). Since the handover occurred on 08.09.2022, s.153C stood excluded by statute, rendering the AO's notices dated 08.09.2022 without authority and contrary to s.153C(3). Consequently, all impugned s.153C notices were quashed and the assessee succeeded. - ITAT
The dominant issue was whether notices issued under s.153C were valid in view of s.153C(3) for searches initiated on or after 01.04.2021. The Tribunal held that the date on which seized material is handed over to the assessee's jurisdictional AO constitutes the "date of initiation of search" for purposes of s.153C(3). Since the handover occurred on 08.09.2022, s.153C stood excluded by statute, rendering the AO's notices dated 08.09.2022 without authority and contrary to s.153C(3). Consequently, all impugned s.153C notices were quashed and the assessee succeeded. - ITAT
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