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 recovery of outstanding tax demand should be stayed under s. 220(6) while the assessee's stay application remained pending. The court held that no mandatory stay could be directed because the assessee's appeal before the ITAT had not yet been restored and the assessee had itself proposed payment of the demand in installments, undermining the basis for compelling a stay; accordingly, stay was refused. The Revenue was directed to decide the assessee's pending stay application under s. 156 expeditiously, preferably within four weeks, without treating the order as any mandate to grant stay. - HC
The dominant issue was whether recovery of outstanding tax demand should be stayed under s. 220(6) while the assessee's stay application remained pending. The court held that no mandatory stay could be directed because the assessee's appeal before the ITAT had not yet been restored and the assessee had itself proposed payment of the demand in installments, undermining the basis for compelling a stay; accordingly, stay was refused. The Revenue was directed to decide the assessee's pending stay application under s. 156 expeditiously, preferably within four weeks, without treating the order as any mandate to grant stay. - HC
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