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...
Issue: Whether penalty proceedings under sections 271D and 271E were barred by limitation. The tribunal held that, applying sections 271D, 271E and 275(1) and following the Supreme Court precedent in Hissaria Brothers, the Assessing Officer's penalty orders were time-barred because they were not issued within the statutory limitation period; the appellate orders setting aside those penalties for being beyond limitation were lawful. Consequence: all four impugned penalty orders were quashed. - ITAT
Issue: Whether penalty proceedings under sections 271D and 271E were barred by limitation. The tribunal held that, applying sections 271D, 271E and 275(1) and following the Supreme Court precedent in Hissaria Brothers, the Assessing Officer's penalty orders were time-barred because they were not issued within the statutory limitation period; the appellate orders setting aside those penalties for being beyond limitation were lawful. Consequence: all four impugned penalty orders were quashed. - ITAT
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