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...
Under GST, a transit State may intercept, inspect and physically verify goods in movement, but that regulatory power does not extend to detention or penalty where the transaction neither originates in nor terminates in that State and no tax is payable there. Cross-empowerment under the State and Central Acts, read with the IGST framework, operates only between authorities dealing with the same State and taxable transaction; it does not authorise one State's GST officers to penalise an inter-State movement passing through its territory. A valid e-way bill and tax invoice, without any allegation of bogus documents or local supply, require only reporting of any documentation defect to the competent authorities in the relevant originating or destination State.
Under GST, a transit State may intercept, inspect and physically verify goods in movement, but that regulatory power does not extend to detention or penalty where the transaction neither originates in nor terminates in that State and no tax is payable there. Cross-empowerment under the State and Central Acts, read with the IGST framework, operates only between authorities dealing with the same State and taxable transaction; it does not authorise one State's GST officers to penalise an inter-State movement passing through its territory. A valid e-way bill and tax invoice, without any allegation of bogus documents or local supply, require only reporting of any documentation defect to the competent authorities in the relevant originating or destination State.
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