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...
Interest under section 234C cannot be levied for advance tax instalments falling due before a newly set up business begins operations, because income from that source was not yet capable of estimation on those dates. Reading section 234C with the proviso to section 3 and clause (c) of the proviso to section 234C(1), the Tribunal held that the assessee's business, which commenced on 17.10.2019, created no obligation to anticipate or pay business advance tax for the June and September instalments. The earlier instalments were excluded, and the interest was directed to be recomputed only for the period after commencement of business.
Interest under section 234C cannot be levied for advance tax instalments falling due before a newly set up business begins operations, because income from that source was not yet capable of estimation on those dates. Reading section 234C with the proviso to section 3 and clause (c) of the proviso to section 234C(1), the Tribunal held that the assessee's business, which commenced on 17.10.2019, created no obligation to anticipate or pay business advance tax for the June and September instalments. The earlier instalments were excluded, and the interest was directed to be recomputed only for the period after commencement of business.
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