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...
Profiteering under the GST framework was found arising from failure to pass on input tax credit; the investigative report's computations were accepted as conclusive and used to quantify profiteering and a proportional adjustment for completed work, resulting in a specified amount payable to the applicant. The respondent is directed to pay the proportionate profiteered amount to the applicant with interest calculated under the CGST Rules and to submit a compliance report to tax authorities within the prescribed timeframe.
Profiteering under the GST framework was found arising from failure to pass on input tax credit; the investigative report's computations were accepted as conclusive and used to quantify profiteering and a proportional adjustment for completed work, resulting in a specified amount payable to the applicant. The respondent is directed to pay the proportionate profiteered amount to the applicant with interest calculated under the CGST Rules and to submit a compliance report to tax authorities within the prescribed timeframe.
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