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...
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
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