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...
Faceless assessment procedure requires that any draft assessment proposing variation prejudicial to the taxpayer be examined and the taxpayer be given an opportunity to show cause before finalisation; failure to communicate such draft and to afford show cause opportunity is a breach of the mandatory procedure. Because the Revenue conceded no draft was communicated and no opportunity was given, the final assessment under section 143(3) and consequent demand notice were quashed for non compliance with the faceless assessment requirements, and the petition disposed of with no order as to costs.
Faceless assessment procedure requires that any draft assessment proposing variation prejudicial to the taxpayer be examined and the taxpayer be given an opportunity to show cause before finalisation; failure to communicate such draft and to afford show cause opportunity is a breach of the mandatory procedure. Because the Revenue conceded no draft was communicated and no opportunity was given, the final assessment under section 143(3) and consequent demand notice were quashed for non compliance with the faceless assessment requirements, and the petition disposed of with no order as to costs.
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