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...
Petition challenged the validity of government notifications and an order under section 73 of the CGST Act; Court held the principal issue was availability of an alternate remedy and directed relegation to statutory appeal against the order dated 26 June 2024, permitting all substantive grounds to be raised on merits - outcome: petition dismissed and appellants relegated to appeal. The Court further held that if the appeal succeeds, challenge to the notifications will be unnecessary, but if the appeal fails, liberty to challenge the notifications is preserved. - HC
Petition challenged the validity of government notifications and an order under section 73 of the CGST Act; Court held the principal issue was availability of an alternate remedy and directed relegation to statutory appeal against the order dated 26 June 2024, permitting all substantive grounds to be raised on merits - outcome: petition dismissed and appellants relegated to appeal. The Court further held that if the appeal succeeds, challenge to the notifications will be unnecessary, but if the appeal fails, liberty to challenge the notifications is preserved. - HC
Note: It is a system-generated summary and is for quick reference only.