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...
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
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