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...
Issue concerned eligibility for deduction under Section 80-IC where assessee manufactured some items listed in the Fourteenth Schedule but not those in the Thirteenth Schedule. Tribunal rejected the Revenue's contention that manufacture of Fourteenth Schedule items alone invoked Section 80-IC(2)(b); instead eligibility was determined by location in a notified eligible area and commencement of production within the specified period. Result: assessee entitled to benefit under Section 80-IC(2)(a)(ii) on satisfying location and commencement criteria, not merely by producing certain Fourteenth Schedule goods.
Issue concerned eligibility for deduction under Section 80-IC where assessee manufactured some items listed in the Fourteenth Schedule but not those in the Thirteenth Schedule. Tribunal rejected the Revenue's contention that manufacture of Fourteenth Schedule items alone invoked Section 80-IC(2)(b); instead eligibility was determined by location in a notified eligible area and commencement of production within the specified period. Result: assessee entitled to benefit under Section 80-IC(2)(a)(ii) on satisfying location and commencement criteria, not merely by producing certain Fourteenth Schedule goods.
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