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...
Section 5 of the Stamp Act applies where a single instrument embodies several distinct matters so that each is separately chargeable; the court found that the NCLT sanction order cannot be dissected into separate instruments for stamp duty by examining underlying transactions. An order originating outside the State is not chargeable under Section 19 merely because it is referenced in a local NCLT order; stamp authorities in the receiving State lack jurisdiction absent receipt or execution within that State. The impugned assessment segregating mergers into distinct transactions was erroneous; the writ is allowed and the assessment orders are quashed and set aside.
Section 5 of the Stamp Act applies where a single instrument embodies several distinct matters so that each is separately chargeable; the court found that the NCLT sanction order cannot be dissected into separate instruments for stamp duty by examining underlying transactions. An order originating outside the State is not chargeable under Section 19 merely because it is referenced in a local NCLT order; stamp authorities in the receiving State lack jurisdiction absent receipt or execution within that State. The impugned assessment segregating mergers into distinct transactions was erroneous; the writ is allowed and the assessment orders are quashed and set aside.
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