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...
A composite property used partly for residence and partly for commercial activity was treated as eligible for section 54 relief to the extent of the residential portion. The Tribunal held that the residential component could not be ignored merely because the sale agreement described the property as commercial, and directed apportionment of sale consideration relating to the residential floors before granting exemption. On the addition under section 56(2)(vii), it held that where the assessee disputed the stamp valuation, the Assessing Officer should have referred the matter to the DVO instead of directly taxing the difference. The valuation issue was remitted for fresh decision.
A composite property used partly for residence and partly for commercial activity was treated as eligible for section 54 relief to the extent of the residential portion. The Tribunal held that the residential component could not be ignored merely because the sale agreement described the property as commercial, and directed apportionment of sale consideration relating to the residential floors before granting exemption. On the addition under section 56(2)(vii), it held that where the assessee disputed the stamp valuation, the Assessing Officer should have referred the matter to the DVO instead of directly taxing the difference. The valuation issue was remitted for fresh decision.
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