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...
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
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