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...
Where an assessee obtained a certificate under the Direct Tax Dispute Resolution Scheme, 2016, the settlement order under s. 204(1) was held conclusive under s. 204(3), barring reopening of matters covered by it under the Act. Consequently, immunity from penalty proceedings operated generally, making it immaterial whether penalty would otherwise fall under s. 271AAB or s. 271AB. A revision initiated on audit objection to direct a de novo penalty order on the premise of applying a different penalty provision was unsustainable, and no substantial question of law arose. - HC
Where an assessee obtained a certificate under the Direct Tax Dispute Resolution Scheme, 2016, the settlement order under s. 204(1) was held conclusive under s. 204(3), barring reopening of matters covered by it under the Act. Consequently, immunity from penalty proceedings operated generally, making it immaterial whether penalty would otherwise fall under s. 271AAB or s. 271AB. A revision initiated on audit objection to direct a de novo penalty order on the premise of applying a different penalty provision was unsustainable, and no substantial question of law arose. - HC
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