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 distinct NP rates applied to separate businesses: AO applied a uniform 8% NP rate to both iron-scrap and livestock sales without any intelligible differentia; books of account contained no pointed defects. Tribunal accepted CIT(A)'s reliance on comparable assessments showing NP rates of 0.15-0.23% for livestock turnover and held that differential cost structures warrant a lower NP rate for animal sales; consequently the 0.22% NP rate was applied to livestock/animal sales and the AO's uniform 8% determination was set aside - ITAT
Whether distinct NP rates applied to separate businesses: AO applied a uniform 8% NP rate to both iron-scrap and livestock sales without any intelligible differentia; books of account contained no pointed defects. Tribunal accepted CIT(A)'s reliance on comparable assessments showing NP rates of 0.15-0.23% for livestock turnover and held that differential cost structures warrant a lower NP rate for animal sales; consequently the 0.22% NP rate was applied to livestock/animal sales and the AO's uniform 8% determination was set aside - ITAT
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