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...
Undervaluation of closing stock was addressed by accepting contemporaneous excise records and purchase ledgers as displacing the Assessing Officer's arithmetic shortfall, the typographical repetition in Form 3CD being found non-determinative; consequence: quantity-based addition deleted. Valuation was held consistent with the accounting principle of lower of cost or net realisable value where the assessee proved stock damage from heavy rains, and the reduced market valuation was accepted; consequence: value-based addition deleted. The AO's separate addition for 'variation in stock' after valuing closing stock was treated as impermissible double addition and deleted; Revenue's appeal dismissed.
Undervaluation of closing stock was addressed by accepting contemporaneous excise records and purchase ledgers as displacing the Assessing Officer's arithmetic shortfall, the typographical repetition in Form 3CD being found non-determinative; consequence: quantity-based addition deleted. Valuation was held consistent with the accounting principle of lower of cost or net realisable value where the assessee proved stock damage from heavy rains, and the reduced market valuation was accepted; consequence: value-based addition deleted. The AO's separate addition for 'variation in stock' after valuing closing stock was treated as impermissible double addition and deleted; Revenue's appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
