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...
The article summarises a High Court decision quashing an FIR and investigation where investigative material failed to identify accused or disclose prima facie deception or dishonest intention at the inception of transactions; the court applied the prohibition on fishing or roving inquiries and held that uncontroverted documentary material negated allegations against the petitioner, warranting quash. It emphasised the distinction between bona fide commercial lending decisions and criminality, noting regulator and ministry oversight, and treated statutory protection for decisions by public servants under Section 17A as a bar to investigating unnamed bank officials without prescribed pre conditions.
The article summarises a High Court decision quashing an FIR and investigation where investigative material failed to identify accused or disclose prima facie deception or dishonest intention at the inception of transactions; the court applied the prohibition on fishing or roving inquiries and held that uncontroverted documentary material negated allegations against the petitioner, warranting quash. It emphasised the distinction between bona fide commercial lending decisions and criminality, noting regulator and ministry oversight, and treated statutory protection for decisions by public servants under Section 17A as a bar to investigating unnamed bank officials without prescribed pre conditions.
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