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...
Validity of electronically issued assessment orders was contested for absence of a DIN and unsigned show cause notices; the HC recorded that the assessment carried a portal-generated Reference No (auto-assigned and exclusive to that assessment) and rejected the challenge to electronic issuance on that basis. The HC also found the petitioner aware of assessment action and unable to explain delay between appeal rejection and writ filing; on the ground of laches the writ petition was dismissed. No substantive grounds raised in the petition were sustained.
Validity of electronically issued assessment orders was contested for absence of a DIN and unsigned show cause notices; the HC recorded that the assessment carried a portal-generated Reference No (auto-assigned and exclusive to that assessment) and rejected the challenge to electronic issuance on that basis. The HC also found the petitioner aware of assessment action and unable to explain delay between appeal rejection and writ filing; on the ground of laches the writ petition was dismissed. No substantive grounds raised in the petition were sustained.
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