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...
Denial of TDS credit arose from non-production of relevant documents; tribunal found tax was lawfully deposited and non-production resulted from a bona fide belief, not malafide, and therefore admission of additional evidence was warranted, with the consequence that the evidence should be admitted and considered. The tribunal directed restoration to the assessing officer to permit the assessee to file additional evidence within a prescribed period and ordered the AO, after verification, to allow the TDS credit as per law; grounds allowed for statistical purposes.
Denial of TDS credit arose from non-production of relevant documents; tribunal found tax was lawfully deposited and non-production resulted from a bona fide belief, not malafide, and therefore admission of additional evidence was warranted, with the consequence that the evidence should be admitted and considered. The tribunal directed restoration to the assessing officer to permit the assessee to file additional evidence within a prescribed period and ordered the AO, after verification, to allow the TDS credit as per law; grounds allowed for statistical purposes.
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