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...
Receipt on premature surrender of a pension policy was held to require examination under section 80CCC(2) in light of the true nature of the amount received. The Tribunal found that the Assessing Officer had taxed it as income from other sources without properly considering the statutory provision, the factual matrix, or the assessee's submissions and documentary evidence. As the reassessment and addition were made without due legal appreciation, the addition was directed to be deleted and the appeal was allowed.
Receipt on premature surrender of a pension policy was held to require examination under section 80CCC(2) in light of the true nature of the amount received. The Tribunal found that the Assessing Officer had taxed it as income from other sources without properly considering the statutory provision, the factual matrix, or the assessee's submissions and documentary evidence. As the reassessment and addition were made without due legal appreciation, the addition was directed to be deleted and the appeal was allowed.
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