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...
ITAT held that an appeal against a rectification order under section 154 cannot be used to challenge the original addition where the rectification merely corrected a computation mistake apparent from the record and did not disturb the substantive assessment. As the assessee's grievance was in substance against the addition itself, the proper remedy was to appeal the original assessment order, not the rectification order. The appeal against the rectification order was therefore rightly dismissed. The Tribunal clarified that this dismissal would not prevent the assessee from separately challenging the original assessment order in accordance with law, subject to limitation, with all contentions left open.
ITAT held that an appeal against a rectification order under section 154 cannot be used to challenge the original addition where the rectification merely corrected a computation mistake apparent from the record and did not disturb the substantive assessment. As the assessee's grievance was in substance against the addition itself, the proper remedy was to appeal the original assessment order, not the rectification order. The appeal against the rectification order was therefore rightly dismissed. The Tribunal clarified that this dismissal would not prevent the assessee from separately challenging the original assessment order in accordance with law, subject to limitation, with all contentions left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
