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...
After a search under section 132 in the assessee's case, the ITAT held that the Assessing Officer could not continue with a normal scrutiny assessment under section 143(3) and had to proceed under the special post-search statutory route. Because the Revenue did not dislodge this jurisdictional defect, the Tribunal found an invalid assumption of jurisdiction and quashed the assessment framed under section 143(3). The grounds challenging the additions on merits were therefore rendered academic.
After a search under section 132 in the assessee's case, the ITAT held that the Assessing Officer could not continue with a normal scrutiny assessment under section 143(3) and had to proceed under the special post-search statutory route. Because the Revenue did not dislodge this jurisdictional defect, the Tribunal found an invalid assumption of jurisdiction and quashed the assessment framed under section 143(3). The grounds challenging the additions on merits were therefore rendered academic.
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