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...
Results declared by the assessee in the return were held unsupported by the books of accounts, and the rejection of the books and consequent income estimation was sustained. A cash deposit during the demonetisation period was held to be explained by retail liquor sales and, since sales were accepted as the source and no other unrecorded utilisation appeared, an addition under unexplained money principles was deleted. A claimed deduction under 80C was disallowed for want of documentary proof; absence of supporting evidence before appellate authorities justified upholding that disallowance.
Results declared by the assessee in the return were held unsupported by the books of accounts, and the rejection of the books and consequent income estimation was sustained. A cash deposit during the demonetisation period was held to be explained by retail liquor sales and, since sales were accepted as the source and no other unrecorded utilisation appeared, an addition under unexplained money principles was deleted. A claimed deduction under 80C was disallowed for want of documentary proof; absence of supporting evidence before appellate authorities justified upholding that disallowance.
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