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...
Reopening of assessment was valid where specific information and documentary material, including affidavits and tally entries naming lenders, connected to the AOs independent formation of belief that income had escaped assessment, establishing a live link and satisfying the tangible material requirement for initiating proceedings; therefore reassessment jurisdiction was sustained. Separately, denial of opportunity to cross-examine a witness whose statement formed the basis of additions violated principles of natural justice; the impugned appellate order is set aside on that issue and the matter is remitted with direction to permit cross-examination.
Reopening of assessment was valid where specific information and documentary material, including affidavits and tally entries naming lenders, connected to the AOs independent formation of belief that income had escaped assessment, establishing a live link and satisfying the tangible material requirement for initiating proceedings; therefore reassessment jurisdiction was sustained. Separately, denial of opportunity to cross-examine a witness whose statement formed the basis of additions violated principles of natural justice; the impugned appellate order is set aside on that issue and the matter is remitted with direction to permit cross-examination.
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