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...
An appellate order directing restoration of GST registration must be implemented unless it is stayed, because mere filing of a further departmental appeal does not create an automatic stay in the absence of statutory provision. The Court found the revenue's refusal to comply with the unstayed direction arbitrary and unreasonable, especially where the appellate authority had already set aside the cancellation refusal and positively ordered restoration. The registration was therefore directed to be revived forthwith, subject to the outcome of the pending departmental appeal.
An appellate order directing restoration of GST registration must be implemented unless it is stayed, because mere filing of a further departmental appeal does not create an automatic stay in the absence of statutory provision. The Court found the revenue's refusal to comply with the unstayed direction arbitrary and unreasonable, especially where the appellate authority had already set aside the cancellation refusal and positively ordered restoration. The registration was therefore directed to be revived forthwith, subject to the outcome of the pending departmental appeal.
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