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...
DIN compliance was treated as mandatory for a GST assessment summary in FORM GST DRC-07; the HC noted that the impugned order carried no DIN and, applying settled law and the CBIC circular, held that the omission affected the validity of the proceeding. On that procedural defect alone, the uploaded assessment summary could not be sustained and was set aside. Liberty was reserved to the authority to undertake fresh assessment after notice and issuance of a DIN-compliant order, with the intervening period excluded for limitation.
DIN compliance was treated as mandatory for a GST assessment summary in FORM GST DRC-07; the HC noted that the impugned order carried no DIN and, applying settled law and the CBIC circular, held that the omission affected the validity of the proceeding. On that procedural defect alone, the uploaded assessment summary could not be sustained and was set aside. Liberty was reserved to the authority to undertake fresh assessment after notice and issuance of a DIN-compliant order, with the intervening period excluded for limitation.
Note: It is a system-generated summary and is for quick reference only.
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