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...
Service of GST notices and the impugned order solely by uploading them under "Additional Notices and Orders" on the GST portal, without any other mode of service, was held insufficient to impute due knowledge to the taxpayer when awareness arose only upon email intimation. Applying the principle that effective service must reasonably convey notice of the proceedings, the Court found that the proceedings had been continued and concluded without proper communication to the taxpayer. Consequently, the impugned order dated 21 May 2025 was set aside and the petition was disposed of. - HC
Service of GST notices and the impugned order solely by uploading them under "Additional Notices and Orders" on the GST portal, without any other mode of service, was held insufficient to impute due knowledge to the taxpayer when awareness arose only upon email intimation. Applying the principle that effective service must reasonably convey notice of the proceedings, the Court found that the proceedings had been continued and concluded without proper communication to the taxpayer. Consequently, the impugned order dated 21 May 2025 was set aside and the petition was disposed of. - HC
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