Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
Challenge to service of the show cause notice (SCN) on the ground that it was uploaded only in the "Additional Notices" tab was rejected, as the portal changes after 16 January 2024 made that tab visible and accessible, and the SCN issued on 17 May 2024 was shown to be available there. However, the adjudication order was held vitiated for breach of natural justice because it was passed without considering the taxpayer's submissions and contentions; additionally, the impugned time-extension notifications were noted to be under challenge before superior judicial forums. The order was set aside, time was granted to file reply to the SCN up to 30 September 2025, and a personal hearing was directed thereafter. - HC
Challenge to service of the show cause notice (SCN) on the ground that it was uploaded only in the "Additional Notices" tab was rejected, as the portal changes after 16 January 2024 made that tab visible and accessible, and the SCN issued on 17 May 2024 was shown to be available there. However, the adjudication order was held vitiated for breach of natural justice because it was passed without considering the taxpayer's submissions and contentions; additionally, the impugned time-extension notifications were noted to be under challenge before superior judicial forums. The order was set aside, time was granted to file reply to the SCN up to 30 September 2025, and a personal hearing was directed thereafter. - HC
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