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...
Relief under the salary-arrear relief provision was considered in relation to exemptions for voluntary retirement payments; the tribunal accepted that gratuity, leave encashment, voluntary retirement compensation and arrears may be exempt and that relief under the arrears-relief provision can be claimed in addition to the statutory exemption. Relying on cited precedents, the tribunal remitted the common computation issue to the assessing officer for verification and recalculation of the arrears relief in accordance with law, directing reasonable opportunity to the assessee and allowing the appeals for statistical purposes.
Relief under the salary-arrear relief provision was considered in relation to exemptions for voluntary retirement payments; the tribunal accepted that gratuity, leave encashment, voluntary retirement compensation and arrears may be exempt and that relief under the arrears-relief provision can be claimed in addition to the statutory exemption. Relying on cited precedents, the tribunal remitted the common computation issue to the assessing officer for verification and recalculation of the arrears relief in accordance with law, directing reasonable opportunity to the assessee and allowing the appeals for statistical purposes.
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