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...
Fair market rent for business premises cannot be enhanced merely on an Inspector's report or comparison with a different property in another city when no credible material shows that a similarly situated property in the same locality would fetch higher rent; the assessee's disclosed rent was accepted as reasonable and the addition for understated rental income was deleted. Salary paid to the assessee's son was treated as genuine business expenditure where the record showed regular engagement in the family business, work at both business locations, past payment history, growing turnover and profits, and taxability in the recipient's hands; the disallowance was set aside and deleted. The appeal was partly allowed, with remaining grounds treated as not pressed or consequential.
Fair market rent for business premises cannot be enhanced merely on an Inspector's report or comparison with a different property in another city when no credible material shows that a similarly situated property in the same locality would fetch higher rent; the assessee's disclosed rent was accepted as reasonable and the addition for understated rental income was deleted. Salary paid to the assessee's son was treated as genuine business expenditure where the record showed regular engagement in the family business, work at both business locations, past payment history, growing turnover and profits, and taxability in the recipient's hands; the disallowance was set aside and deleted. The appeal was partly allowed, with remaining grounds treated as not pressed or consequential.
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