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...
Mandating a digital signature to complete an e-assessment is a jurisdictional formality; where the assessment order, computation and demand notice lacked the mandatory digital signature and were effectively antedated, the reassessment was held time-barred and invalid. Separately, the tribunal upheld the appellate finding allowing an extraordinary business loss for fire damage to the extent supported by documentary evidence and insurer reimbursement, concluding revenue failed to overturn those factual findings. The revenue appeal was dismissed, the reassessment quashed for want of mandatory signature and limitation, and the deletion of the addition for the exceptional loss sustained.
Mandating a digital signature to complete an e-assessment is a jurisdictional formality; where the assessment order, computation and demand notice lacked the mandatory digital signature and were effectively antedated, the reassessment was held time-barred and invalid. Separately, the tribunal upheld the appellate finding allowing an extraordinary business loss for fire damage to the extent supported by documentary evidence and insurer reimbursement, concluding revenue failed to overturn those factual findings. The revenue appeal was dismissed, the reassessment quashed for want of mandatory signature and limitation, and the deletion of the addition for the exceptional loss sustained.
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