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...
Where an assessing officer treated an amount shown as outstanding in the assessee's balance-sheet as unexplained income, the Tribunal accepted that bank account statements and TDS challans (including TDS payment with interest and late fee) evidencing subsequent payment sufficiently established the outstanding liability; the sale deeds' recital of full receipt without recording mode of payment did not override documentary banking evidence. On that basis the Tribunal held the Section 69A addition unsustainable and deleted the addition, allowing the assessee's appeal for the relevant assessment year.
Where an assessing officer treated an amount shown as outstanding in the assessee's balance-sheet as unexplained income, the Tribunal accepted that bank account statements and TDS challans (including TDS payment with interest and late fee) evidencing subsequent payment sufficiently established the outstanding liability; the sale deeds' recital of full receipt without recording mode of payment did not override documentary banking evidence. On that basis the Tribunal held the Section 69A addition unsustainable and deleted the addition, allowing the assessee's appeal for the relevant assessment year.
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