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...
Deduction for gratuity actually paid under section 43B was allowed because the assessee substantiated actual payment with audited financial statements, actuarial provision entries, profit and loss account debit, gratuity disclosures, and supporting ledger and salary records. The Tribunal held that the evidentiary record proved payment to the relevant employees and that the disallowance based on alleged absence of proof was factually unsustainable. The deletion of the disallowance was therefore upheld and the claim for deduction was allowed.
Deduction for gratuity actually paid under section 43B was allowed because the assessee substantiated actual payment with audited financial statements, actuarial provision entries, profit and loss account debit, gratuity disclosures, and supporting ledger and salary records. The Tribunal held that the evidentiary record proved payment to the relevant employees and that the disallowance based on alleged absence of proof was factually unsustainable. The deletion of the disallowance was therefore upheld and the claim for deduction was allowed.
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