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...
Whether a registered person could be permitted to file a manual GSTR-3B for the quarter ending March 2021 to claim additional ITC omitted due to an error was determined by balancing procedural facilitation with preservation of existing tax demands. The court accepted that allowing manual filing would not, by itself, nullify or dilute the demand raised under the order dated 19.02.2025, which would continue to operate subject to any permissible challenge before the competent authority. Accordingly, the respondents were directed to accept the manual return, without automatic impact on the demand order, and the petition was disposed of. - HC
Whether a registered person could be permitted to file a manual GSTR-3B for the quarter ending March 2021 to claim additional ITC omitted due to an error was determined by balancing procedural facilitation with preservation of existing tax demands. The court accepted that allowing manual filing would not, by itself, nullify or dilute the demand raised under the order dated 19.02.2025, which would continue to operate subject to any permissible challenge before the competent authority. Accordingly, the respondents were directed to accept the manual return, without automatic impact on the demand order, and the petition was disposed of. - HC
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