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...
Assessment of trust expenditure centred on whether claimed expenses demonstrated application of income for charitable purposes; the tribunal accepted documentary evidence (salary registers, salary ledgers, cash book, bank book, payment records and other ledger accounts) and agreed with the CIT(A) that the assessing officer offered no basis to disallow a portion of expenses. The appellate panel found the majority of costs were salary-related and substantiated, noted no infirmity in the remaining ledgers, and dismissed the revenue appeal for lack of contrary evidential foundation.
Assessment of trust expenditure centred on whether claimed expenses demonstrated application of income for charitable purposes; the tribunal accepted documentary evidence (salary registers, salary ledgers, cash book, bank book, payment records and other ledger accounts) and agreed with the CIT(A) that the assessing officer offered no basis to disallow a portion of expenses. The appellate panel found the majority of costs were salary-related and substantiated, noted no infirmity in the remaining ledgers, and dismissed the revenue appeal for lack of contrary evidential foundation.
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