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...
Assessee failed to establish eligibility for immunity under section 270AA(3) because no application in Form 68-online or manual-was produced or acknowledged; alleged technical glitch was unsubstantiated. The reasoning applies the requirement that an immunity application must be filed and evidenced, and that absence of Form 68 or acknowledgment supports a finding of under reporting. Consequent to these factual and evidentiary findings, penalty liability under section 270A was sustained and the appeal was dismissed.
Assessee failed to establish eligibility for immunity under section 270AA(3) because no application in Form 68-online or manual-was produced or acknowledged; alleged technical glitch was unsubstantiated. The reasoning applies the requirement that an immunity application must be filed and evidenced, and that absence of Form 68 or acknowledgment supports a finding of under reporting. Consequent to these factual and evidentiary findings, penalty liability under section 270A was sustained and the appeal was dismissed.
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