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 assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
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