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...
Assessment orders passed under the GST scheme in respect of periods including March, April, June and July 2023 are set aside and the affected taxpayer is permitted to have belated returns taken on record; authorities are permitted to examine and adjudicate liability thereafter under the applicable assessment provisions (including proceedings under substantive assessment provisions) in accordance with law. All other contentions remain open. The taxpayer is directed to pay Rs.25,000 to the High Court Legal Services Authority as costs.
Assessment orders passed under the GST scheme in respect of periods including March, April, June and July 2023 are set aside and the affected taxpayer is permitted to have belated returns taken on record; authorities are permitted to examine and adjudicate liability thereafter under the applicable assessment provisions (including proceedings under substantive assessment provisions) in accordance with law. All other contentions remain open. The taxpayer is directed to pay Rs.25,000 to the High Court Legal Services Authority as costs.
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