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...
Official certificates and revenue records admitted by the first appellate authority were treated as properly relied upon because they went to the root of the dispute and no specific prejudice to the Revenue was shown. On the merits, the land was accepted as rural agricultural land on the basis of urban development authority certificates, revenue records and census data showing it lay beyond the prescribed municipal distance. As the Assessing Officer produced no independent verification or conclusive contrary evidence, the lands were held to fall outside section 2(14) and outside section 194-IA, so the assessee could not be treated as an assessee in default under section 201(1) and interest under section 201(1A) was not sustainable.
Official certificates and revenue records admitted by the first appellate authority were treated as properly relied upon because they went to the root of the dispute and no specific prejudice to the Revenue was shown. On the merits, the land was accepted as rural agricultural land on the basis of urban development authority certificates, revenue records and census data showing it lay beyond the prescribed municipal distance. As the Assessing Officer produced no independent verification or conclusive contrary evidence, the lands were held to fall outside section 2(14) and outside section 194-IA, so the assessee could not be treated as an assessee in default under section 201(1) and interest under section 201(1A) was not sustainable.
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