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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...
The DRP's directions are binding on the Assessing Officer, and a final assessment under section 144C must conform to those directions. Here, the Assessing Officer issued the final order by repeating the transfer pricing adjustment from the draft assessment, despite DRP directions requiring the adjustment to be reworked and the consequential effect order reflecting a reduced figure. The Tribunal treated this as a serious breach of the statutory mandate and quashed the final assessment order without any further inquiry into prejudice. The merits of the additions were left undecided.
The DRP's directions are binding on the Assessing Officer, and a final assessment under section 144C must conform to those directions. Here, the Assessing Officer issued the final order by repeating the transfer pricing adjustment from the draft assessment, despite DRP directions requiring the adjustment to be reworked and the consequential effect order reflecting a reduced figure. The Tribunal treated this as a serious breach of the statutory mandate and quashed the final assessment order without any further inquiry into prejudice. The merits of the additions were left undecided.
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