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 a registered sale deed was subsequently cancelled by a registered cancellation deed and the purchaser's share of the sale consideration was repaid as recorded in the cancellation deed, there was no subsisting transfer or benefit taxable as imputed income under the gifts/imputed-income provision; the cancellation with repayment removed the legal basis for treating the difference between stamp valuation and declared consideration as income, and the addition made on that ground was deleted with the appeal allowed.
Where a registered sale deed was subsequently cancelled by a registered cancellation deed and the purchaser's share of the sale consideration was repaid as recorded in the cancellation deed, there was no subsisting transfer or benefit taxable as imputed income under the gifts/imputed-income provision; the cancellation with repayment removed the legal basis for treating the difference between stamp valuation and declared consideration as income, and the addition made on that ground was deleted with the appeal allowed.
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