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...
Liability of the deductor arises where tax required to be deducted at source was not deducted or deposited and there is no evidence that the payees paid tax directly; the deductor must produce a prescribed certificate confirming payee payment. Because no such certificate or information about payee payments was found, the tribunal remanded the matter to the assessing officer to examine whether payees paid tax and to reconsider treating the deductor as an assessee in default. An additional ground was allowed for statistical purposes.
Liability of the deductor arises where tax required to be deducted at source was not deducted or deposited and there is no evidence that the payees paid tax directly; the deductor must produce a prescribed certificate confirming payee payment. Because no such certificate or information about payee payments was found, the tribunal remanded the matter to the assessing officer to examine whether payees paid tax and to reconsider treating the deductor as an assessee in default. An additional ground was allowed for statistical purposes.
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