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 of employees' provident fund contribution was upheld following binding precedent; consequence: contribution remains disallowed for tax purposes. Provision for leave encashment computed actuarially was held to be an ascertained business liability and allowable as a deduction. Deduction under section 80G for CSR-linked donations was permitted where payments lacked quid pro quo, preventing double disallowance. Claims for DDT credit and interest were remitted to the Assessing Officer for factual verification and record scrutiny. Year end ad hoc expense provision reversed in a subsequent year was allowed as a deduction. Additions for short term capital gains and late deposited contributions were ordered verified and deleted if shown to be factually incorrect.
Disallowance of employees' provident fund contribution was upheld following binding precedent; consequence: contribution remains disallowed for tax purposes. Provision for leave encashment computed actuarially was held to be an ascertained business liability and allowable as a deduction. Deduction under section 80G for CSR-linked donations was permitted where payments lacked quid pro quo, preventing double disallowance. Claims for DDT credit and interest were remitted to the Assessing Officer for factual verification and record scrutiny. Year end ad hoc expense provision reversed in a subsequent year was allowed as a deduction. Additions for short term capital gains and late deposited contributions were ordered verified and deleted if shown to be factually incorrect.
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