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...
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
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