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...
Addition under section 40A(3) challenged on facts showing freight payments were not made in cash to a single driver exceeding the statutory limit, and the appellate authority found records and affidavits supporting that payments were direct to drivers, resulting in deletion of the addition. Addition for alleged unrecorded cash payment based on mobile messages was deleted because the messages were unauthenticated, no verification or enquiry was made of the purported recipients, books were not rejected, and there was no corroborative evidence, leading to deletion.
Addition under section 40A(3) challenged on facts showing freight payments were not made in cash to a single driver exceeding the statutory limit, and the appellate authority found records and affidavits supporting that payments were direct to drivers, resulting in deletion of the addition. Addition for alleged unrecorded cash payment based on mobile messages was deleted because the messages were unauthenticated, no verification or enquiry was made of the purported recipients, books were not rejected, and there was no corroborative evidence, leading to deletion.
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