Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
An APA covering the relevant year required the Arm's Length Price for international transactions to be reconsidered with reference to the APA terms, so the Assessing Officer was directed to rework the transfer pricing adjustment in accordance with law. The MAT book profit adjustment was also sent back because the assessment order did not discuss the addition and the assessee had not been given an opportunity of hearing; the officer was directed to reconsider the book profit computation after hearing the assessee and in light of the section 143(1) intimation. The interest and fee computation was remanded for verification of the extended due date, and interest under section 234B was held mandatory, subject to consequential recomputation after giving effect to the revised figures.
An APA covering the relevant year required the Arm's Length Price for international transactions to be reconsidered with reference to the APA terms, so the Assessing Officer was directed to rework the transfer pricing adjustment in accordance with law. The MAT book profit adjustment was also sent back because the assessment order did not discuss the addition and the assessee had not been given an opportunity of hearing; the officer was directed to reconsider the book profit computation after hearing the assessee and in light of the section 143(1) intimation. The interest and fee computation was remanded for verification of the extended due date, and interest under section 234B was held mandatory, subject to consequential recomputation after giving effect to the revised figures.
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