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...
Under Section 144C the Dispute Resolution Panel (DRP) should have dismissed the petitioner's objections simpliciter because a final assessment order had already been passed; therefore the DRP's findings on whether the objections were intimated to the assessing officer were unwarranted. The operative effect directed is that those DRP observations shall not be considered by the Commissioner of Income Tax (Appeals), who must decide the taxpayer's appeal against the final assessment order without being influenced by the impugned DRP order.
Under Section 144C the Dispute Resolution Panel (DRP) should have dismissed the petitioner's objections simpliciter because a final assessment order had already been passed; therefore the DRP's findings on whether the objections were intimated to the assessing officer were unwarranted. The operative effect directed is that those DRP observations shall not be considered by the Commissioner of Income Tax (Appeals), who must decide the taxpayer's appeal against the final assessment order without being influenced by the impugned DRP order.
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