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...
ITAT addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
ITAT addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
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