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...
Penalty for failure to comply with statutory notices was set aside because notices issued via the tax portal were not communicated and an exparte assessment under the notice scheme was passed. The assessee activated an efiling account only after the assessment order and became aware of proceedings later; the appellate authority condoned delay in filing the appeal and reopened the assessment. The tribunal found that noncommunication amounted to a reasonable cause for noncompliance and deleted the penalty. Appeal by the revenue was dismissed and penalty removed.
Penalty for failure to comply with statutory notices was set aside because notices issued via the tax portal were not communicated and an exparte assessment under the notice scheme was passed. The assessee activated an efiling account only after the assessment order and became aware of proceedings later; the appellate authority condoned delay in filing the appeal and reopened the assessment. The tribunal found that noncommunication amounted to a reasonable cause for noncompliance and deleted the penalty. Appeal by the revenue was dismissed and penalty removed.
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