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...
The article addresses penalty proceedings under section 271D for alleged contravention of section 269SS: tribunals have held that cash received as part of sale consideration expressly recorded in a registered sale deed may fall outside the prohibition on specified cash receipts, and penalty cannot stand where the Assessing Officer has not recorded satisfaction in assessment proceedings. It further notes limitation rulings applying the TOLA extension as making show-cause notices issued well after the extended reasonable period time-barred; on those grounds the impugned penalty was deleted and the assessee's appeal allowed.
The article addresses penalty proceedings under section 271D for alleged contravention of section 269SS: tribunals have held that cash received as part of sale consideration expressly recorded in a registered sale deed may fall outside the prohibition on specified cash receipts, and penalty cannot stand where the Assessing Officer has not recorded satisfaction in assessment proceedings. It further notes limitation rulings applying the TOLA extension as making show-cause notices issued well after the extended reasonable period time-barred; on those grounds the impugned penalty was deleted and the assessee's appeal allowed.
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