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...
Tribunal addressed estimated additions made by the AO over recorded purchase and sales without first rejecting the books of account under applicable provisions; it held that where the AO accepts the genuineness of books he cannot independently compute estimated unrecorded sales or commission income without invoking rejection/estimation provisions, and such additions are arbitrary and unlawful. The Tribunal directed deletion of the estimated addition and allowed the appeal, applying precedent that books must be rejected before making estimation-based additions.
Tribunal addressed estimated additions made by the AO over recorded purchase and sales without first rejecting the books of account under applicable provisions; it held that where the AO accepts the genuineness of books he cannot independently compute estimated unrecorded sales or commission income without invoking rejection/estimation provisions, and such additions are arbitrary and unlawful. The Tribunal directed deletion of the estimated addition and allowed the appeal, applying precedent that books must be rejected before making estimation-based additions.
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