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...
Forensic audit expenses incurred in aid of the Asset Disposal Committee's asset-disposal functions were treated as incidental and therefore payable by the Committee, including the fees of the Chartered Accountant firm engaged for that purpose. The Court also directed the Union of India to frame a reimbursement mechanism if sale realisations ultimately fall short of the amounts raised through the scheme. In the investor restitution framework, the Court permitted SDMS to be engaged to ensure continuity and speed, ordered transfer of website credentials, digital records and updated application materials from WEBEL, and issued consequential directions for further action against assets not yet attached or not in the physical possession of the Enforcement Directorate.
Forensic audit expenses incurred in aid of the Asset Disposal Committee's asset-disposal functions were treated as incidental and therefore payable by the Committee, including the fees of the Chartered Accountant firm engaged for that purpose. The Court also directed the Union of India to frame a reimbursement mechanism if sale realisations ultimately fall short of the amounts raised through the scheme. In the investor restitution framework, the Court permitted SDMS to be engaged to ensure continuity and speed, ordered transfer of website credentials, digital records and updated application materials from WEBEL, and issued consequential directions for further action against assets not yet attached or not in the physical possession of the Enforcement Directorate.
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