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...
Classification dispute concerned MS tanks, frames and gland plates: applying the commercial identity test and purchaser-supplied drawings and certificates, the tribunal concluded these items are parts of electrical transformers and correctly classifiable under CTH 85049010; contemporaneous ER-1 returns and departmental knowledge of clearances precluded invocation of the extended period of limitation, so the demand was set aside and impugned order quashed with consequential relief.
Classification dispute concerned MS tanks, frames and gland plates: applying the commercial identity test and purchaser-supplied drawings and certificates, the tribunal concluded these items are parts of electrical transformers and correctly classifiable under CTH 85049010; contemporaneous ER-1 returns and departmental knowledge of clearances precluded invocation of the extended period of limitation, so the demand was set aside and impugned order quashed with consequential relief.
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