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...
Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
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