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...
Refund of unutilized input tax credit under the Central GST framework was contested due to failure to satisfy export of services conditions under IGST; the agency/intermediary characterisation of the petitioners role with respect to the parent entity required reassessment. The appellate authority is directed to re-examine contractual clauses, the applicability of relevant circulars and the Sundyne Pumps precedent, and record specific findings. The impugned administrative order is quashed and the matter is remitted for de novo consideration and a fresh decision in accordance with law.
Refund of unutilized input tax credit under the Central GST framework was contested due to failure to satisfy export of services conditions under IGST; the agency/intermediary characterisation of the petitioners role with respect to the parent entity required reassessment. The appellate authority is directed to re-examine contractual clauses, the applicability of relevant circulars and the Sundyne Pumps precedent, and record specific findings. The impugned administrative order is quashed and the matter is remitted for de novo consideration and a fresh decision in accordance with law.
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