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 receipt of export remittance under the CGST framework requires a reasoned order and opportunity for hearing; a mere communication or intimation cannot substitute for an order. The impugned communication purportedly rejecting the petitioner's representation was not a reasoned order and no hearing was afforded. The matter is remitted to the competent commissioner to reconsider the condonation request afresh, afford the petitioner an opportunity to be heard, and pass a reasoned decision addressing the grounds raised by the petitioner.
Condonation of delay in receipt of export remittance under the CGST framework requires a reasoned order and opportunity for hearing; a mere communication or intimation cannot substitute for an order. The impugned communication purportedly rejecting the petitioner's representation was not a reasoned order and no hearing was afforded. The matter is remitted to the competent commissioner to reconsider the condonation request afresh, afford the petitioner an opportunity to be heard, and pass a reasoned decision addressing the grounds raised by the petitioner.
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