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...
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
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