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...
Amendment to clause (c) of section 200A relating to imposition of late fee under section 234E applies prospectively from 01.06.2015; therefore late fee for belated TDS quarterly returns must be calculated only from that date to the date of filing. Coordinate bench authority directs recalculation of late fee from 01.06.2015; appellate order set aside and matter remitted to the jurisdictional TDS officer to perform the specified recalculation and determine payable late fee for the relevant return period.
Amendment to clause (c) of section 200A relating to imposition of late fee under section 234E applies prospectively from 01.06.2015; therefore late fee for belated TDS quarterly returns must be calculated only from that date to the date of filing. Coordinate bench authority directs recalculation of late fee from 01.06.2015; appellate order set aside and matter remitted to the jurisdictional TDS officer to perform the specified recalculation and determine payable late fee for the relevant return period.
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