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...
Bogus purchase additions under section 69C were discussed in the context of whether the assessee had discharged the burden of proving genuineness; the note states that purchase invoices, supplier ledgers, transport receipts, banking records and regular books supported the transactions, and that a mere reversal of input tax credit did not by itself establish non-genuine purchases. It also addresses reassessment under section 148, stating that notice and the section 148A(d) order were not in accordance with law where the reopening was based on DGGI/Insight information, the material was not supplied to the assessee, and no independent application of mind was shown. The addition and reopening are described as unsustainable on those facts.
Bogus purchase additions under section 69C were discussed in the context of whether the assessee had discharged the burden of proving genuineness; the note states that purchase invoices, supplier ledgers, transport receipts, banking records and regular books supported the transactions, and that a mere reversal of input tax credit did not by itself establish non-genuine purchases. It also addresses reassessment under section 148, stating that notice and the section 148A(d) order were not in accordance with law where the reopening was based on DGGI/Insight information, the material was not supplied to the assessee, and no independent application of mind was shown. The addition and reopening are described as unsustainable on those facts.
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