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...
Whether the assessee's investments in group/subsidiary companies constituted "business" so as to allow related expenditure and consequent set-off of loss was the dominant issue. The Tribunal held that the assessee's main object was to make strategic investments in such companies, and the investments made were in furtherance of that object; hence, the activity amounted to business within s.2(13) and the expenditure was incidental thereto, warranting allowance as business expenditure. Having accepted the resultant current-year business loss, the Tribunal directed that it be set off against interest income assessed under "Income from other sources" in accordance with s.71, and allowed the appeal. - ITAT
Whether the assessee's investments in group/subsidiary companies constituted "business" so as to allow related expenditure and consequent set-off of loss was the dominant issue. The Tribunal held that the assessee's main object was to make strategic investments in such companies, and the investments made were in furtherance of that object; hence, the activity amounted to business within s.2(13) and the expenditure was incidental thereto, warranting allowance as business expenditure. Having accepted the resultant current-year business loss, the Tribunal directed that it be set off against interest income assessed under "Income from other sources" in accordance with s.71, and allowed the appeal. - ITAT
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