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...
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
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