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...
Disallowance of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
Disallowance of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
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