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 recalculated and adopted a fair market value for land at the time of its conversion into stock in trade but failed to apply that same value when computing business income and cost of acquisition, generating a mistake apparent on record. The appellate authority corrected this by treating the fair market value at conversion as the cost for subsequent business profit computation, deleting the addition. The tribunal found the appellate officer properly exercised appellate powers under the statute to rectify the evident error and upheld the appellate order, deciding against the revenue.
Assessing Officer recalculated and adopted a fair market value for land at the time of its conversion into stock in trade but failed to apply that same value when computing business income and cost of acquisition, generating a mistake apparent on record. The appellate authority corrected this by treating the fair market value at conversion as the cost for subsequent business profit computation, deleting the addition. The tribunal found the appellate officer properly exercised appellate powers under the statute to rectify the evident error and upheld the appellate order, deciding against the revenue.
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