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...
High Court granted liberty to prefer a statutory GST appeal subject to a conditional extension and provisional deposit: the petitioner may file the appeal within 30 days on payment of 50% of the disputed tax, failing which the appeal must be dismissed and recovery may proceed as if the writ were dismissed. The court held that a bank overdraft account cannot be attached, but the revenue may pursue movable and immovable assets offered as security, subject to the bank's rights and the outcome of the appeal. The order disposes of the writ with these operative conditions.
High Court granted liberty to prefer a statutory GST appeal subject to a conditional extension and provisional deposit: the petitioner may file the appeal within 30 days on payment of 50% of the disputed tax, failing which the appeal must be dismissed and recovery may proceed as if the writ were dismissed. The court held that a bank overdraft account cannot be attached, but the revenue may pursue movable and immovable assets offered as security, subject to the bank's rights and the outcome of the appeal. The order disposes of the writ with these operative conditions.
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