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...
Block assessment scope under Chapter XIV-B is governed by the definition of "block period"; where an Assessment Year falls within that period Section 158BA(2) causes pending proceedings to abate insofar as they relate to the block period. The court held that (re)assessment for AY 2022 23 falls within the block period conceptually, but denied writ relief because factual prerequisites were not established-no material showed the search disclosed the petitioner's total undisclosed income or linked company searches to his individual income-so the AO retains jurisdiction under Chapter XIV B if statutory conditions are met.
Block assessment scope under Chapter XIV-B is governed by the definition of "block period"; where an Assessment Year falls within that period Section 158BA(2) causes pending proceedings to abate insofar as they relate to the block period. The court held that (re)assessment for AY 2022 23 falls within the block period conceptually, but denied writ relief because factual prerequisites were not established-no material showed the search disclosed the petitioner's total undisclosed income or linked company searches to his individual income-so the AO retains jurisdiction under Chapter XIV B if statutory conditions are met.
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