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...
Ten-year block computation was governed by the operative date of the satisfaction note (29-09-2021), which placed AYs 2011-12 and 2012-13 outside the ten-year block and resulted in quashing of those assessments. Separately, the assumption of jurisdiction under the search-related provision was held invalid because the seized material did not contain incriminating information attributable to the assessee; verbatim satisfaction notes, a non contemporaneous excel sheet created by searched person staff and lack of corroboration defeated evidentiary value. Consequent additions were deleted and the revenue appeals dismissed.
Ten-year block computation was governed by the operative date of the satisfaction note (29-09-2021), which placed AYs 2011-12 and 2012-13 outside the ten-year block and resulted in quashing of those assessments. Separately, the assumption of jurisdiction under the search-related provision was held invalid because the seized material did not contain incriminating information attributable to the assessee; verbatim satisfaction notes, a non contemporaneous excel sheet created by searched person staff and lack of corroboration defeated evidentiary value. Consequent additions were deleted and the revenue appeals dismissed.
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