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...
Income declared under the IDS-2016 became chargeable to tax under the Income-tax Act in the previous year in which the declaration was made when the declarant failed to pay the tax, surcharge and penalty within the prescribed time. As the declaration was filed on 28.09.2016, the Tribunal held that the Revenue could not reopen and assess that amount in AY 2013-14. The reassessment and corresponding addition for that year were therefore unsustainable in law, and the addition was deleted.
Income declared under the IDS-2016 became chargeable to tax under the Income-tax Act in the previous year in which the declaration was made when the declarant failed to pay the tax, surcharge and penalty within the prescribed time. As the declaration was filed on 28.09.2016, the Tribunal held that the Revenue could not reopen and assess that amount in AY 2013-14. The reassessment and corresponding addition for that year were therefore unsustainable in law, and the addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
