Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
Reassessment was challenged on the validity of "reasons to believe" and the requirement of a live link between material and alleged escapement of income. The recorded reasons were internally contradictory, alternately stating that no return was filed and that declared income did not match cash deposits, showing uncertainty on foundational facts. The AO relied merely on AIR data of cash deposits without any independent analysis or tangible material explaining the nature of transactions or connecting deposits to undisclosed income, rendering the reasons vague and lacking rational nexus. Consequently, the reassessment initiation was held invalid and the assessee's ground was allowed - ITAT
Reassessment was challenged on the validity of "reasons to believe" and the requirement of a live link between material and alleged escapement of income. The recorded reasons were internally contradictory, alternately stating that no return was filed and that declared income did not match cash deposits, showing uncertainty on foundational facts. The AO relied merely on AIR data of cash deposits without any independent analysis or tangible material explaining the nature of transactions or connecting deposits to undisclosed income, rendering the reasons vague and lacking rational nexus. Consequently, the reassessment initiation was held invalid and the assessee's ground was allowed - ITAT
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