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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...
Dispute concerns multiple corporate assessment adjustments: the tribunal held depreciation disallowance unsustainable where assets were purchased through banking channels, recorded in audited books and legitimately owned and used, and directed deletion. Warranty provision deduction was recalculated and remitted to the AO to grant the correct deductible amount. Rental receipts from trailer leasing were held to be business income, not income from house property, and relevant additions were deleted. Carry forward of losses was remitted for correct computation. TDS shortfall claims were ordered verified with submitted evidence. Addition on share premium was deleted as consideration received from a non-resident is outside the relevant taxable scope. Ad hoc disallowances on vehicle repairs and residual settlements were deleted; depreciation on plant and verification of put-to-use dates was directed to AO.
Dispute concerns multiple corporate assessment adjustments: the tribunal held depreciation disallowance unsustainable where assets were purchased through banking channels, recorded in audited books and legitimately owned and used, and directed deletion. Warranty provision deduction was recalculated and remitted to the AO to grant the correct deductible amount. Rental receipts from trailer leasing were held to be business income, not income from house property, and relevant additions were deleted. Carry forward of losses was remitted for correct computation. TDS shortfall claims were ordered verified with submitted evidence. Addition on share premium was deleted as consideration received from a non-resident is outside the relevant taxable scope. Ad hoc disallowances on vehicle repairs and residual settlements were deleted; depreciation on plant and verification of put-to-use dates was directed to AO.
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