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Reopening of assessment u/s 147 - Change of opinion - TP ...


Reopening Assessments u/s 147 Unjustified for Transfer Pricing Adjustments Due to Change of Opinion, Say Courts.

February 17, 2022

Case Laws     Income Tax     HC

Reopening of assessment u/s 147 - Change of opinion - TP adjustment addition - Courts have repeatedly held that once a query is raised and that has been explained by the assessee, even if there is no discussion on that aspect in the assessment order still the Assessing Officer is deemed to have consider these points and applied his mind. - All these only indicate one thing that re-opening is proposed on the basis of change of opinion. - HC

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