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...
Cessation of liability under tax law was not attracted where long-standing foreign trade creditors remained recorded as liabilities and were not written off in the year under review; alleged waivers were reflected and offered to tax only in a later year. The legal principle applied required a cessation of liability in the year and a corresponding benefit to the taxpayer in cash, kind or otherwise; absent evidence that liabilities ceased or that the taxpayer became richer by remission during the year, the prior addition under the cessation rule was deleted.
Cessation of liability under tax law was not attracted where long-standing foreign trade creditors remained recorded as liabilities and were not written off in the year under review; alleged waivers were reflected and offered to tax only in a later year. The legal principle applied required a cessation of liability in the year and a corresponding benefit to the taxpayer in cash, kind or otherwise; absent evidence that liabilities ceased or that the taxpayer became richer by remission during the year, the prior addition under the cessation rule was deleted.
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