Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
Violation of natural justice and entitlement to personal hearing is addressed in the context of writ jurisdiction and availability of statutory appellate remedy; where a statutory forum exists and is functional, the writ remedy should be relegated and the statutory appeal procedure followed, including compliance with any conditions attached to filing such appeal (pre-deposit requirement), and the writ court must not bypass those conditions. The petition was disposed directing availing of the appellate forum without expressing opinion on merits, and interlocutory applications stood disposed.
Violation of natural justice and entitlement to personal hearing is addressed in the context of writ jurisdiction and availability of statutory appellate remedy; where a statutory forum exists and is functional, the writ remedy should be relegated and the statutory appeal procedure followed, including compliance with any conditions attached to filing such appeal (pre-deposit requirement), and the writ court must not bypass those conditions. The petition was disposed directing availing of the appellate forum without expressing opinion on merits, and interlocutory applications stood disposed.
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