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...
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
