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...
In bogus purchase matters, the ITAT held that disallowance could not rest solely on search statements where section 133(6) notices were complied with and confirmations, returns and Form 16A were produced; with sales not treated as unexplained and the books not rejected, deletion of the major disallowance was upheld. For two parties that did not respond and did not furnish confirmations or returns, the Tribunal sustained only a 5% disallowance on the remaining purchases, without precedent effect. In the unexplained money issue, ticket sale receipts were duly explained on record, so deletion of the section 69A addition was confirmed. The Revenue's appeals failed.
In bogus purchase matters, the ITAT held that disallowance could not rest solely on search statements where section 133(6) notices were complied with and confirmations, returns and Form 16A were produced; with sales not treated as unexplained and the books not rejected, deletion of the major disallowance was upheld. For two parties that did not respond and did not furnish confirmations or returns, the Tribunal sustained only a 5% disallowance on the remaining purchases, without precedent effect. In the unexplained money issue, ticket sale receipts were duly explained on record, so deletion of the section 69A addition was confirmed. The Revenue's appeals failed.
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