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...
TDS under section 194I applies to annual lease rent paid to a development authority, focusing on the scope of the term "rent" as the dominant issue; the present facts mirror prior authority and no substantial distinction was shown, so the authority of the earlier judgment requiring TDS on such payments was applied and the appeals were rejected. The prior decision was held to operate prospectively from its date, and its subsequent judicial affirmation was noted. The question left open by this decision remains available for later resolution.
TDS under section 194I applies to annual lease rent paid to a development authority, focusing on the scope of the term "rent" as the dominant issue; the present facts mirror prior authority and no substantial distinction was shown, so the authority of the earlier judgment requiring TDS on such payments was applied and the appeals were rejected. The prior decision was held to operate prospectively from its date, and its subsequent judicial affirmation was noted. The question left open by this decision remains available for later resolution.
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