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...
The Tribunal reduced an estimated business profit rate from the rates adopted by the tax authorities to 4% of turnover, noting the absence of reliable comparable cases and the assessee's lower historical profits in the wholesale medicine trade. It also cancelled penalty for delayed filing of the audit report under section 271B, accepting reasonable cause where the assessee relied on a tax consultant and lived in a remote area. Further, it deleted the remaining penalty for non-compliance with notices under section 271(1)(b), holding that the same reasonable cause applied and that some defaults had already been effectively waived.
The Tribunal reduced an estimated business profit rate from the rates adopted by the tax authorities to 4% of turnover, noting the absence of reliable comparable cases and the assessee's lower historical profits in the wholesale medicine trade. It also cancelled penalty for delayed filing of the audit report under section 271B, accepting reasonable cause where the assessee relied on a tax consultant and lived in a remote area. Further, it deleted the remaining penalty for non-compliance with notices under section 271(1)(b), holding that the same reasonable cause applied and that some defaults had already been effectively waived.
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