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...
For computing limitation for a final assessment after DRP directions, the operative date is the date the directions are intimated and uploaded on the ITBA portal with DIN, because that upload constitutes communication and receipt by the Assessing Officer. The Tribunal rejected the Revenue's contention that time should run only from later physical receipt of the directions. Applying that rule, the final assessment orders were passed beyond the prescribed period and were therefore time-barred and invalid. The orders were quashed, and the appeals were partly allowed, with other issues left open.
For computing limitation for a final assessment after DRP directions, the operative date is the date the directions are intimated and uploaded on the ITBA portal with DIN, because that upload constitutes communication and receipt by the Assessing Officer. The Tribunal rejected the Revenue's contention that time should run only from later physical receipt of the directions. Applying that rule, the final assessment orders were passed beyond the prescribed period and were therefore time-barred and invalid. The orders were quashed, and the appeals were partly allowed, with other issues left open.
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