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...
Permission to file a statutory appeal was considered by condoning a 478-day delay to determine admissibility; the court quashed the impugned assessment order and remitted the matter to the original authority for fresh adjudication on merits. The remand was made conditional on the petitioner depositing the entire tax amount confirmed in the assessment from its electronic cash register within thirty days of receipt of the order. The time-bar under the GST appeal regime and the deposit requirement governed the court's operative relief.
Permission to file a statutory appeal was considered by condoning a 478-day delay to determine admissibility; the court quashed the impugned assessment order and remitted the matter to the original authority for fresh adjudication on merits. The remand was made conditional on the petitioner depositing the entire tax amount confirmed in the assessment from its electronic cash register within thirty days of receipt of the order. The time-bar under the GST appeal regime and the deposit requirement governed the court's operative relief.
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