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...
Reconciliation statement dispute regarding an extended period of limitation under section 74 was not addressed by the adjudicating authority, which recorded perfunctory observations; the authority is directed to re-examine the limitation contention and the assertion of having supplied the reconciliation statement and to afford the petitioner an opportunity of hearing before passing a fresh order. The adjudicating authority must deal substantively with the limitation issue and factual assertions and issue a reconsidered order within twelve weeks from receipt of the direction.
Reconciliation statement dispute regarding an extended period of limitation under section 74 was not addressed by the adjudicating authority, which recorded perfunctory observations; the authority is directed to re-examine the limitation contention and the assertion of having supplied the reconciliation statement and to afford the petitioner an opportunity of hearing before passing a fresh order. The adjudicating authority must deal substantively with the limitation issue and factual assertions and issue a reconsidered order within twelve weeks from receipt of the direction.
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