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 initiating officer validly recorded "reasons to believe" before issuing notice under section 24(1) for provisional attachment under the benami law. It was held that the reasons were recorded in writing and duly disclosed within the show cause notice; there is no statutory requirement to separately furnish a copy of such reasons, and the notice reflected analysis of statements and bank records, so the challenge failed. On merits, receipt of demonetised cash in the appellant's bank account, followed by RTGS transfers to beneficiaries, was treated as strong evidence of a benami arrangement, and the claimed business explanation remained unsubstantiated; the appeal was dismissed. - AT
The dominant issue was whether the initiating officer validly recorded "reasons to believe" before issuing notice under section 24(1) for provisional attachment under the benami law. It was held that the reasons were recorded in writing and duly disclosed within the show cause notice; there is no statutory requirement to separately furnish a copy of such reasons, and the notice reflected analysis of statements and bank records, so the challenge failed. On merits, receipt of demonetised cash in the appellant's bank account, followed by RTGS transfers to beneficiaries, was treated as strong evidence of a benami arrangement, and the claimed business explanation remained unsubstantiated; the appeal was dismissed. - AT
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