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...
Expunction of adverse observations in insolvency-related proceedings where appellate review found paras 25 and 28 contained unsupported factual assertions. The document holds that findings about initiation of investigation and group company affiliation lacked admissible material and were therefore unsustainable, and that exclusion of any Committee of Creditors member requires adequate opportunity to be heard; accordingly the impugned observations were expunged and related directions set aside. The operative effect is removal of unsupported adverse findings and affirmation of the necessity of evidentiary basis and hearing before excluding a CoC member.
Expunction of adverse observations in insolvency-related proceedings where appellate review found paras 25 and 28 contained unsupported factual assertions. The document holds that findings about initiation of investigation and group company affiliation lacked admissible material and were therefore unsustainable, and that exclusion of any Committee of Creditors member requires adequate opportunity to be heard; accordingly the impugned observations were expunged and related directions set aside. The operative effect is removal of unsupported adverse findings and affirmation of the necessity of evidentiary basis and hearing before excluding a CoC member.
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