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...
Where the assessee failed to produce cogent evidence of employment, salary receipt, commission or brokerage, the Tribunal upheld denial of the claimed standard deduction and treated the returned income as unexplained money under section 69A for A.Ys. 2019-20 and 2020-21. By contrast, where the assessee had opted for presumptive taxation under section 44AD and produced confirmations, sample bills and related business details, the Tribunal accepted that rice trading business was carried on and held that the same receipts could not again be taxed as unexplained money under section 69A, as that would amount to double taxation. The section 69A addition was deleted for A.Y. 2022-23, and the rice trading finding was applied for A.Y. 2021-22.
Where the assessee failed to produce cogent evidence of employment, salary receipt, commission or brokerage, the Tribunal upheld denial of the claimed standard deduction and treated the returned income as unexplained money under section 69A for A.Ys. 2019-20 and 2020-21. By contrast, where the assessee had opted for presumptive taxation under section 44AD and produced confirmations, sample bills and related business details, the Tribunal accepted that rice trading business was carried on and held that the same receipts could not again be taxed as unexplained money under section 69A, as that would amount to double taxation. The section 69A addition was deleted for A.Y. 2022-23, and the rice trading finding was applied for A.Y. 2021-22.
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