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...
Deemed income assessment under section 69A was sustained where the AO established that the assessee had introduced and facilitated opening of 9,165 bank accounts and withdrawals from those accounts; the onus rested on the assessee to prove the nature and source of the unexplained amounts and it failed to do so. The Tribunal held ownership of withdrawn amounts as an indicium of income and rejected the CIT(A)'s finding that the assessee was merely a facilitator and not responsible for irregular accounts, thereby confirming additions for the assessment year.
Deemed income assessment under section 69A was sustained where the AO established that the assessee had introduced and facilitated opening of 9,165 bank accounts and withdrawals from those accounts; the onus rested on the assessee to prove the nature and source of the unexplained amounts and it failed to do so. The Tribunal held ownership of withdrawn amounts as an indicium of income and rejected the CIT(A)'s finding that the assessee was merely a facilitator and not responsible for irregular accounts, thereby confirming additions for the assessment year.
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