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...
Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
Note: It is a system-generated summary and is for quick reference only.