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...
Disallowance under the cash-payment restriction was contested for director remuneration; the tribunal examined ledger entries and found no single-day cash payment exceeding the statutory cash threshold because salaries were paid monthly. The legal basis addressed was whether cash disbursements contravened the prohibition on large cash payments to related parties; finding no violation, the tribunal held the disallowance unjustified and allowed the claim in favour of the taxpayer.
Disallowance under the cash-payment restriction was contested for director remuneration; the tribunal examined ledger entries and found no single-day cash payment exceeding the statutory cash threshold because salaries were paid monthly. The legal basis addressed was whether cash disbursements contravened the prohibition on large cash payments to related parties; finding no violation, the tribunal held the disallowance unjustified and allowed the claim in favour of the taxpayer.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
