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...
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
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