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...
VCES benefit denied because the declarant failed to pay the mandatory 50% pre deposit by the specified cut off date and filed a declaration barred by the second proviso to Section 106(1) for a subsequent period where an order of determination already existed; the designated authority validly rejected the declaration after due process. The tribunal held that the scheme's procedural timetable and stipulations are inviolable, that courts cannot extend amnesty timelines, and that the designated authority possesses inherent and ancillary powers to scrutinise and refuse nonconforming declarations. The appellate challenge was dismissed for lack of merit.
VCES benefit denied because the declarant failed to pay the mandatory 50% pre deposit by the specified cut off date and filed a declaration barred by the second proviso to Section 106(1) for a subsequent period where an order of determination already existed; the designated authority validly rejected the declaration after due process. The tribunal held that the scheme's procedural timetable and stipulations are inviolable, that courts cannot extend amnesty timelines, and that the designated authority possesses inherent and ancillary powers to scrutinise and refuse nonconforming declarations. The appellate challenge was dismissed for lack of merit.
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