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...
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
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