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...
HC declined to entertain the Revenue's departmental appeal because the amount involved fell below the monetary threshold prescribed in the circular dated 06.08.2024. The Court also found that the Tribunal's order did not raise any substantial question of law on merits. On both grounds, the appeal was dismissed, along with the connected application.
HC declined to entertain the Revenue's departmental appeal because the amount involved fell below the monetary threshold prescribed in the circular dated 06.08.2024. The Court also found that the Tribunal's order did not raise any substantial question of law on merits. On both grounds, the appeal was dismissed, along with the connected application.
Note: It is a system-generated summary and is for quick reference only.