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...
Allegations of professional misconduct against counsel for filing an appeal on oral/client instructions were rejected because the record showed no misconduct and the filing was under bona fide instructions; consequently, no direction for payment of 18% interest or litigation costs was warranted on that basis. The appellate order dismissing the underlying appeal for non-rectification of defects under Rule 26(3)-(4) was affirmed, and the proceeding was closed. In view of frivolous and false imputations that undermine the legal profession, liberty was reserved to the affected counsel to initiate criminal proceedings for malicious prosecution against the appellant. - NCLAT
Allegations of professional misconduct against counsel for filing an appeal on oral/client instructions were rejected because the record showed no misconduct and the filing was under bona fide instructions; consequently, no direction for payment of 18% interest or litigation costs was warranted on that basis. The appellate order dismissing the underlying appeal for non-rectification of defects under Rule 26(3)-(4) was affirmed, and the proceeding was closed. In view of frivolous and false imputations that undermine the legal profession, liberty was reserved to the affected counsel to initiate criminal proceedings for malicious prosecution against the appellant. - NCLAT
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