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...
Petitioners sought accommodation for videography of statement recordings and presence of counsel during summons in a GST summons inquiry, asserting genuine transactions, banked payments, and pending appeals by suppliers. The petitioner with serious illness sought humanitarian consideration; petitioners offered cooperation. The court accepted a limited, non precedential accommodation-permitting videography and humane treatment consistent with cooperation-and directed disposal on terms similar to a prior coordinate bench order, while noting the relief is exceptional and fact specific.
Petitioners sought accommodation for videography of statement recordings and presence of counsel during summons in a GST summons inquiry, asserting genuine transactions, banked payments, and pending appeals by suppliers. The petitioner with serious illness sought humanitarian consideration; petitioners offered cooperation. The court accepted a limited, non precedential accommodation-permitting videography and humane treatment consistent with cooperation-and directed disposal on terms similar to a prior coordinate bench order, while noting the relief is exceptional and fact specific.
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