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...
Under GST rules a revocation application requires prior filing of returns and payment of dues; limitation exists to ensure statutory compliance and protect third party rights, but cancellation of GST registration typically prejudices only the assessee and not third parties. The writ court may condone delay in statutory or quasi judicial proceedings, and on that basis the High Court set aside the dismissal of the appeal for limitation and directed the Appellate Authority to re hear and decide the revocation of cancellation on merits, permitting reconsideration rather than rejection on time bar grounds.
Under GST rules a revocation application requires prior filing of returns and payment of dues; limitation exists to ensure statutory compliance and protect third party rights, but cancellation of GST registration typically prejudices only the assessee and not third parties. The writ court may condone delay in statutory or quasi judicial proceedings, and on that basis the High Court set aside the dismissal of the appeal for limitation and directed the Appellate Authority to re hear and decide the revocation of cancellation on merits, permitting reconsideration rather than rejection on time bar grounds.
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