Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
Unaccounted production addition was deleted because the comparison made by the AO was between unlike units, treating tablets/capsules in production charts as if they were strips in sales records. The Court accepted the concurrent findings of the CIT(A) and Tribunal that this erroneous comparison made the computation unsustainable. It also noted that there was no corroborative material showing excess raw material purchases, unaccounted manufacturing expenditure, or receipt of unaccounted sale proceeds, even after search. The Revenue's challenge was therefore confined to factual issues, and the appeal was dismissed for want of any substantial question of law.
Unaccounted production addition was deleted because the comparison made by the AO was between unlike units, treating tablets/capsules in production charts as if they were strips in sales records. The Court accepted the concurrent findings of the CIT(A) and Tribunal that this erroneous comparison made the computation unsustainable. It also noted that there was no corroborative material showing excess raw material purchases, unaccounted manufacturing expenditure, or receipt of unaccounted sale proceeds, even after search. The Revenue's challenge was therefore confined to factual issues, and the appeal was dismissed for want of any substantial question of law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
