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...
The provisional attachment of the petitioner's bank account had ceased to operate by efflux of the statutory period under Section 83(2), so the attachment could not continue beyond one year. The Court therefore declared the attachment lapsed by operation of law and held that the petitioner was entitled to operate the bank account, while leaving all other contentions open.
The provisional attachment of the petitioner's bank account had ceased to operate by efflux of the statutory period under Section 83(2), so the attachment could not continue beyond one year. The Court therefore declared the attachment lapsed by operation of law and held that the petitioner was entitled to operate the bank account, while leaving all other contentions open.
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