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...
CESTAT addressed condonation of delay and proof-of-delivery requirements in a service tax appeal: the Tribunal directed deposit of a cost to condone inordinate delay in filing the appeal and linked grant of appeal number to compliance; it recognised that statutory ''acknowledgement due'' evidence (AD card or Speed Post tracking showing actual receipt) is mandatory for proving service, and in its absence the department must maintain and produce such proof to prevent frivolous admissions; the Tribunal noted recovery steps including bank account freezing and directed communication of this order to CBIC for systemic remedy.
CESTAT addressed condonation of delay and proof-of-delivery requirements in a service tax appeal: the Tribunal directed deposit of a cost to condone inordinate delay in filing the appeal and linked grant of appeal number to compliance; it recognised that statutory ''acknowledgement due'' evidence (AD card or Speed Post tracking showing actual receipt) is mandatory for proving service, and in its absence the department must maintain and produce such proof to prevent frivolous admissions; the Tribunal noted recovery steps including bank account freezing and directed communication of this order to CBIC for systemic remedy.
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