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...
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
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