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...
Receipt characterised as income from house property where transferee of infrastructure business stepped into transferor's position and continued licence payments; licence fees retained the character of rent arising from use of immovable property, so amounts already offered under Income from House Property cannot be subjected to a fresh addition. Assessing Officer must verify the assessee's computation and give effect to the appellate direction to ensure no double addition is made, treating the CNIL receipt as income from house property.
Receipt characterised as income from house property where transferee of infrastructure business stepped into transferor's position and continued licence payments; licence fees retained the character of rent arising from use of immovable property, so amounts already offered under Income from House Property cannot be subjected to a fresh addition. Assessing Officer must verify the assessee's computation and give effect to the appellate direction to ensure no double addition is made, treating the CNIL receipt as income from house property.
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