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...
Condonation of delay in filing appeals against AAR orders is limited to a maximum extension of 30 days beyond the normal 30 day appeal period; the Appellate Authority (AAAR) lacks power to extend beyond that statutory window, so appeals filed beyond that limit must be rejected as time barred without consideration of merits. Rule permitting manual filing where electronic filing is prescribed does not excuse delay caused by non uploading of an order on the portal. The note also records the classificatory issue that transactions in immovable property may be outside Schedule III but treated as a service under Schedule II clause 5(e), though merits were not reached due to time bar.
Condonation of delay in filing appeals against AAR orders is limited to a maximum extension of 30 days beyond the normal 30 day appeal period; the Appellate Authority (AAAR) lacks power to extend beyond that statutory window, so appeals filed beyond that limit must be rejected as time barred without consideration of merits. Rule permitting manual filing where electronic filing is prescribed does not excuse delay caused by non uploading of an order on the portal. The note also records the classificatory issue that transactions in immovable property may be outside Schedule III but treated as a service under Schedule II clause 5(e), though merits were not reached due to time bar.
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