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...
Appellate authority failed to apply independent mind by paraphrasing the adjudicating authority and neglecting the petitioner's explanations and documents on record; the HC found the appellate order uninformed and susceptible to judicial reproach. The court held that the appellate order does not reveal consideration of submissions or file documents and therefore set aside the impugned order and remanded the matter for fresh merits consideration by the appellate authority, directing proper examination of the petitioner's grounds and documents on record.
Appellate authority failed to apply independent mind by paraphrasing the adjudicating authority and neglecting the petitioner's explanations and documents on record; the HC found the appellate order uninformed and susceptible to judicial reproach. The court held that the appellate order does not reveal consideration of submissions or file documents and therefore set aside the impugned order and remanded the matter for fresh merits consideration by the appellate authority, directing proper examination of the petitioner's grounds and documents on record.
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