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...
Extension of time for filing the appeal granted until 16-3-2026 with express protection that if filed by that date the appeal shall not be dismissed on limitation and shall be adjudicated on merits; pre-deposit requirement for the statutory appeal does not preclude this relief as the petition is disposed of on that basis. The court declined to interfere with the impugned High Court order and disposed of the Special Leave Petition subject to the time-extension and non-dismissal on limitation safeguard.
Extension of time for filing the appeal granted until 16-3-2026 with express protection that if filed by that date the appeal shall not be dismissed on limitation and shall be adjudicated on merits; pre-deposit requirement for the statutory appeal does not preclude this relief as the petition is disposed of on that basis. The court declined to interfere with the impugned High Court order and disposed of the Special Leave Petition subject to the time-extension and non-dismissal on limitation safeguard.
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