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...
Unexplained credit claims for a spousal gift were not accepted on the record because the assessee failed to produce contemporaneous bank statements or a clear mode of transfer and material discrepancies existed in the donor's tax schedules; the AO lacked effective opportunity to verify late-disclosed details. Applying the prima facie onus for unexplained credits, the Tribunal remitted the matter to the jurisdictional AO for fresh adjudication and directed the assessee to furnish complete documentary evidence and permitted factual verification before any addition is made.
Unexplained credit claims for a spousal gift were not accepted on the record because the assessee failed to produce contemporaneous bank statements or a clear mode of transfer and material discrepancies existed in the donor's tax schedules; the AO lacked effective opportunity to verify late-disclosed details. Applying the prima facie onus for unexplained credits, the Tribunal remitted the matter to the jurisdictional AO for fresh adjudication and directed the assessee to furnish complete documentary evidence and permitted factual verification before any addition is made.
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