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...
Provisional attachment under the CGST regime ceases by efflux of time after one year, so orders issued beyond that statutory period are no longer enforceable; consequence-such attachments cannot be continued. Because the provisional order has ceased, neither the tax authority nor the taxpayer's banker may lawfully maintain freezes on the taxpayer's property or bank accounts; consequence-the bank must defreeze accounts held under that expired order. The writ challenge was partly allowed to give effect to the cessation of the provisional attachment and to lift the continued restraints that post dated the one year period.
Provisional attachment under the CGST regime ceases by efflux of time after one year, so orders issued beyond that statutory period are no longer enforceable; consequence-such attachments cannot be continued. Because the provisional order has ceased, neither the tax authority nor the taxpayer's banker may lawfully maintain freezes on the taxpayer's property or bank accounts; consequence-the bank must defreeze accounts held under that expired order. The writ challenge was partly allowed to give effect to the cessation of the provisional attachment and to lift the continued restraints that post dated the one year period.
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