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...
Deduction for political donations was contested on grounds that the recipient party was a tainted conduit for accommodation entries; the assessee bore the onus to substantiate genuineness. The assessing officer produced no evidence of commission, reciprocal payments, or a direct nexus showing benefit to the assessee from the recipient party. On that basis the Tribunal affirmed that the addition could not be sustained and decided against the revenue, noting that CIT(A)/NFAC had previously deleted the addition for lack of proof.
Deduction for political donations was contested on grounds that the recipient party was a tainted conduit for accommodation entries; the assessee bore the onus to substantiate genuineness. The assessing officer produced no evidence of commission, reciprocal payments, or a direct nexus showing benefit to the assessee from the recipient party. On that basis the Tribunal affirmed that the addition could not be sustained and decided against the revenue, noting that CIT(A)/NFAC had previously deleted the addition for lack of proof.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
