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...
Non-communication of a prior court order rendered the subsequent assessment order invalid and was set aside; the assessing officer who issued a draft order is held not at fault due to a communication gap. The transfer pricing officer has supplied relied agreements and the taxpayer is directed to file a reply by the prescribed date, after which the transfer pricing officer must pass a fresh order. All procedural timelines before the transfer pricing officer, assessing officer and dispute resolution panel are extended by sixty days, and the taxpayer is precluded from objecting to that extension.
Non-communication of a prior court order rendered the subsequent assessment order invalid and was set aside; the assessing officer who issued a draft order is held not at fault due to a communication gap. The transfer pricing officer has supplied relied agreements and the taxpayer is directed to file a reply by the prescribed date, after which the transfer pricing officer must pass a fresh order. All procedural timelines before the transfer pricing officer, assessing officer and dispute resolution panel are extended by sixty days, and the taxpayer is precluded from objecting to that extension.
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