Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
Validity of revision under assessment revision power was contested where AO allowed exemption for investment in venture capital undertakings; HC/ITAT found AO had applied mind after detailed enquiry, making PCITs substitution of opinion impermissible, and restored the assessment. Tribunal noted investments taxed in unit holders hands so revenue suffered no prejudice, SEBI VCF Regulations permit temporary mutual fund investments, and the VCF Regulations (post amendment) no longer exclude real estate, so investments in real estate VCUs did not breach regulatory eligibility for the exemption.
Validity of revision under assessment revision power was contested where AO allowed exemption for investment in venture capital undertakings; HC/ITAT found AO had applied mind after detailed enquiry, making PCITs substitution of opinion impermissible, and restored the assessment. Tribunal noted investments taxed in unit holders hands so revenue suffered no prejudice, SEBI VCF Regulations permit temporary mutual fund investments, and the VCF Regulations (post amendment) no longer exclude real estate, so investments in real estate VCUs did not breach regulatory eligibility for the exemption.
Note: It is a system-generated summary and is for quick reference only.