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...
Where an appellant cannot upload an appeal on the common electronic portal because the portal refuses filing absent deposit of a separate demand item, the office must accept a manually filed appeal; the core legal point is that a technical or procedural barrier on the e filing system that prevents initiation of an appeal constitutes a valid ground for manual presentation and obliges the appellate authority to receive and process the appeal manually.
Where an appellant cannot upload an appeal on the common electronic portal because the portal refuses filing absent deposit of a separate demand item, the office must accept a manually filed appeal; the core legal point is that a technical or procedural barrier on the e filing system that prevents initiation of an appeal constitutes a valid ground for manual presentation and obliges the appellate authority to receive and process the appeal manually.
Note: It is a system-generated summary and is for quick reference only.
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