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...
The text addresses revision jurisdiction over income-tax assessments concerning professional and technical fees, sundry creditors, notional interest under Ind AS, and stock valuation. On the alleged difference for professional and technical fees, the record shows AO queries, assessee replies and supporting documents, therefore the revisional finding was contrary to record and unsustainable. On addition of sundry creditors, a debit (trade receivable) was shown and incorporated in P&L, so the revisional addition was factually incorrect and unsustainable. On notional interest, reconciliation with Form 26AS and balance sheet showed no variation, so the revisional action was unwarranted. On stock valuation, AO failed adequate inquiry into valuation method and consistency, so the revisional concern is upheld.
The text addresses revision jurisdiction over income-tax assessments concerning professional and technical fees, sundry creditors, notional interest under Ind AS, and stock valuation. On the alleged difference for professional and technical fees, the record shows AO queries, assessee replies and supporting documents, therefore the revisional finding was contrary to record and unsustainable. On addition of sundry creditors, a debit (trade receivable) was shown and incorporated in P&L, so the revisional addition was factually incorrect and unsustainable. On notional interest, reconciliation with Form 26AS and balance sheet showed no variation, so the revisional action was unwarranted. On stock valuation, AO failed adequate inquiry into valuation method and consistency, so the revisional concern is upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
