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...
Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
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