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...
Belated filing of Form 10B was treated as a procedural lapse that should not defeat exemption claims under sections 11 and 12 in the peculiar facts of the case. Relying on the principle that technical defaults should not override substantive entitlement, and following prior precedent, the Tribunal directed the Assessing Officer to treat the trust's Form 10B as filed within time and process the return accordingly. The appeal was thus allowed, with the delayed filing not being permitted to deny the claimed charitable exemption.
Belated filing of Form 10B was treated as a procedural lapse that should not defeat exemption claims under sections 11 and 12 in the peculiar facts of the case. Relying on the principle that technical defaults should not override substantive entitlement, and following prior precedent, the Tribunal directed the Assessing Officer to treat the trust's Form 10B as filed within time and process the return accordingly. The appeal was thus allowed, with the delayed filing not being permitted to deny the claimed charitable exemption.
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