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...
Interpretation of the faceless assessment scheme finds that a local assessing officer lacks jurisdiction to issue notices or orders outside the electronic faceless mechanism created under the E Assessment Scheme notified under Section 151A; notices and orders issued by the jurisdictional assessing officer outside that mechanism are invalid. Applying that interpretation, the impugned notices and orders were quashed and the assessee's writ succeeded, with relief granted against actions taken by the jurisdictional assessing officer contrary to the faceless assessment procedure.
Interpretation of the faceless assessment scheme finds that a local assessing officer lacks jurisdiction to issue notices or orders outside the electronic faceless mechanism created under the E Assessment Scheme notified under Section 151A; notices and orders issued by the jurisdictional assessing officer outside that mechanism are invalid. Applying that interpretation, the impugned notices and orders were quashed and the assessee's writ succeeded, with relief granted against actions taken by the jurisdictional assessing officer contrary to the faceless assessment procedure.
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