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 directed petitioner to file an appeal under the Finance Act, 1994 within fifteen days and ordered that if the appeal is filed within that period the appellate authority shall not raise limitation objection because a certified copy of the adjudication order was supplied; petitioner must file the certified copy with the Appellate Authority within seven days of receipt. Subject to statutory formalities (other than limitation), the appeal must be admitted and decided on merits; writ petition disposed of accordingly.
High Court directed petitioner to file an appeal under the Finance Act, 1994 within fifteen days and ordered that if the appeal is filed within that period the appellate authority shall not raise limitation objection because a certified copy of the adjudication order was supplied; petitioner must file the certified copy with the Appellate Authority within seven days of receipt. Subject to statutory formalities (other than limitation), the appeal must be admitted and decided on merits; writ petition disposed of accordingly.
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