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...
Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
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