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...
Presumption as to ownership of seized material does not permit altering recorded figures in seized documents without independent corroboration; speculative reconstruction of numeric entries (adding two zeros) is inadmissible and additions under unexplained investment and consequential interest founded solely on that hypothesis are deleted. Entries on loose sheets described as estimates likewise lack corroboration and cannot support additions, and a retracted statement under seizure has no standalone evidentiary value. Result: deletions of additions based on speculative diary alteration and uncorroborated loose-sheet entries; ownership of the diary acknowledged but cannot substitute for independent proof.
Presumption as to ownership of seized material does not permit altering recorded figures in seized documents without independent corroboration; speculative reconstruction of numeric entries (adding two zeros) is inadmissible and additions under unexplained investment and consequential interest founded solely on that hypothesis are deleted. Entries on loose sheets described as estimates likewise lack corroboration and cannot support additions, and a retracted statement under seizure has no standalone evidentiary value. Result: deletions of additions based on speculative diary alteration and uncorroborated loose-sheet entries; ownership of the diary acknowledged but cannot substitute for independent proof.
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