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...
An appellate authority dealing with one assessment year cannot issue directions affecting reopening for earlier years, because its jurisdiction is confined to the year under appeal. The Tribunal held that the Commissioner (Appeals) went beyond the scope of the appeal by directing reopening of earlier assessment years, so that direction was beyond competence and had to be expunged. The separate validity of reopening under section 150 was left unexamined, as the matter was resolved on lack of appellate jurisdiction alone.
An appellate authority dealing with one assessment year cannot issue directions affecting reopening for earlier years, because its jurisdiction is confined to the year under appeal. The Tribunal held that the Commissioner (Appeals) went beyond the scope of the appeal by directing reopening of earlier assessment years, so that direction was beyond competence and had to be expunged. The separate validity of reopening under section 150 was left unexamined, as the matter was resolved on lack of appellate jurisdiction alone.
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