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...
Penalty under section 271AAB was contested on the ground that the search team failed to examine or ascertain the source of cash and jewellery and did not inform searched persons of the disclosure obligation under section 132(4); the failure of authorised officers to question and elicit disclosures was held determinative of the penalty rate, leading to the conclusion that the lesser statutory penalty rate should apply. The assessing officer was directed to recompute the penalty at the lower rate and the assessee's appeal was allowed.
Penalty under section 271AAB was contested on the ground that the search team failed to examine or ascertain the source of cash and jewellery and did not inform searched persons of the disclosure obligation under section 132(4); the failure of authorised officers to question and elicit disclosures was held determinative of the penalty rate, leading to the conclusion that the lesser statutory penalty rate should apply. The assessing officer was directed to recompute the penalty at the lower rate and the assessee's appeal was allowed.
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