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...
Habeas corpus petition found maintainable where remand order was not in accordance with law, rendering the arrest illegal; court applied the "reasons to believe" standard to assess whether arrest relied on credible evidence or mere suspicion and found remand record silent on that inquiry, undermining exercise of arrest powers under the special statute. Failure to show service of grounds of arrest and non compliance with departmental arrest guidelines led the court to hold the remand order legally infirm and to set it aside, allowing the writ.
Habeas corpus petition found maintainable where remand order was not in accordance with law, rendering the arrest illegal; court applied the "reasons to believe" standard to assess whether arrest relied on credible evidence or mere suspicion and found remand record silent on that inquiry, undermining exercise of arrest powers under the special statute. Failure to show service of grounds of arrest and non compliance with departmental arrest guidelines led the court to hold the remand order legally infirm and to set it aside, allowing the writ.
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