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...
TDS credit claims not reflected in Form 26AS require AO verification before allowance; the appellate direction permitting credit where Form 26AS shows TDS, or where the assessee produces evidence plus an indemnity bond, is valid only if the AO conducts necessary verification. The Tribunal found CIT(A) did not mandate unconditional credit but correctly required verification and therefore dismissed Revenue's challenge and the assessee's cross-objection, upholding that credits may be allowed after the AO's appropriate verification.
TDS credit claims not reflected in Form 26AS require AO verification before allowance; the appellate direction permitting credit where Form 26AS shows TDS, or where the assessee produces evidence plus an indemnity bond, is valid only if the AO conducts necessary verification. The Tribunal found CIT(A) did not mandate unconditional credit but correctly required verification and therefore dismissed Revenue's challenge and the assessee's cross-objection, upholding that credits may be allowed after the AO's appropriate verification.
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