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...
Where the assessee's books of account, stock registers and primary records were accepted and not rejected, the article explains that additions treating cash bank deposits as unexplained credits cannot stand absent cogent material displacing the books; the Assessing Officer's reliance on generalized suspicion, timing clusters, third party bank information, survey observations or post facto VAT revisions was held insufficient to rebut the assessee's prima facie explanation. The practical effect emphasised is that accepted and audited books, without specific defect shown by independent inquiry, prevail over speculative or circumstantial indicia when challenging cash deposits.
Where the assessee's books of account, stock registers and primary records were accepted and not rejected, the article explains that additions treating cash bank deposits as unexplained credits cannot stand absent cogent material displacing the books; the Assessing Officer's reliance on generalized suspicion, timing clusters, third party bank information, survey observations or post facto VAT revisions was held insufficient to rebut the assessee's prima facie explanation. The practical effect emphasised is that accepted and audited books, without specific defect shown by independent inquiry, prevail over speculative or circumstantial indicia when challenging cash deposits.
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