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 an assessee may file an updated return under Section 139(8A) once assessment proceedings are pending: the court interpreted clause (b) of the third proviso to s.139(8A) to allow no updated return for the relevant year where assessment/reassessment/recomputation or revision proceedings are pending or completed; therefore the AO correctly refused the updated ITR request after initiation of s.143(2)/assessment u/s 143(3) r/w s.144B and proceeded to disallow exemptions and deductions on merits - request rejected and assessment sustained; appellate remedy preserved. - HC
Whether an assessee may file an updated return under Section 139(8A) once assessment proceedings are pending: the court interpreted clause (b) of the third proviso to s.139(8A) to allow no updated return for the relevant year where assessment/reassessment/recomputation or revision proceedings are pending or completed; therefore the AO correctly refused the updated ITR request after initiation of s.143(2)/assessment u/s 143(3) r/w s.144B and proceeded to disallow exemptions and deductions on merits - request rejected and assessment sustained; appellate remedy preserved. - HC
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