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...
Payment for independent contractor services for MIS reporting, stock verification and marketing were found to be business-necessary and allowable where rendered by unrelated and independent entities and supported by reports and inventory certificates; therefore the examiner's blanket disallowance based on perceived unreasonableness was rejected and books of account were not struck. Comparative per-location cost differences alone did not justify disallowance absent evidence of fictitiousness or lack of service, and the assessee's long experience and engagement terms were held relevant. The appellant's grounds to allow these contract expenses were accepted and the appeal was allowed.
Payment for independent contractor services for MIS reporting, stock verification and marketing were found to be business-necessary and allowable where rendered by unrelated and independent entities and supported by reports and inventory certificates; therefore the examiner's blanket disallowance based on perceived unreasonableness was rejected and books of account were not struck. Comparative per-location cost differences alone did not justify disallowance absent evidence of fictitiousness or lack of service, and the assessee's long experience and engagement terms were held relevant. The appellant's grounds to allow these contract expenses were accepted and the appeal was allowed.
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