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...
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
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