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...
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
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