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...
Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
