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 furnished exhaustive entries and supporting documents for professional fees, all subjected to TDS, establishing genuineness of the expenses; therefore the assessing officer's adhoc 50% disallowance was unsustainable and the appellate authority erred in upholding it. On that basis the disallowance was deleted and the assessee's appeal allowed, the decision reversing the earlier finding because documentary proof and TDS deduction negated any reason to doubt the professional charges claimed.
Assessee furnished exhaustive entries and supporting documents for professional fees, all subjected to TDS, establishing genuineness of the expenses; therefore the assessing officer's adhoc 50% disallowance was unsustainable and the appellate authority erred in upholding it. On that basis the disallowance was deleted and the assessee's appeal allowed, the decision reversing the earlier finding because documentary proof and TDS deduction negated any reason to doubt the professional charges claimed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
