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...
Gifts from parents and near relatives were accepted as genuine where the recipient disclosed name, address, relationship, quantum and confirming PAN-linked declarations, and the addition was deleted for lack of enquiry or cogent rebuttal by the AO. Cash professional receipts were accepted where the assessee produced client names, income-tax return copies and student IDs for tuition, and the addition was deleted. Cash withdrawals shown in the partnership cashbook and admitted as withdrawals by the partnership were treated as personal withdrawals, not undisclosed income, and the corresponding addition was deleted.
Gifts from parents and near relatives were accepted as genuine where the recipient disclosed name, address, relationship, quantum and confirming PAN-linked declarations, and the addition was deleted for lack of enquiry or cogent rebuttal by the AO. Cash professional receipts were accepted where the assessee produced client names, income-tax return copies and student IDs for tuition, and the addition was deleted. Cash withdrawals shown in the partnership cashbook and admitted as withdrawals by the partnership were treated as personal withdrawals, not undisclosed income, and the corresponding addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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