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...
Proviso to sub rule (4) of Rule 22 of the CGST Rules permits an empowered officer to drop cancellation proceedings under Section 29(2)(c) if the person furnishes all pending returns and makes full payment of tax, interest and late fee, and to pass Form GST REG 20; restoration follows on compliance. The petitioner may apply for restoration within two months and the authority must consider and, if requirements are met, restore registration expeditiously. Computation of limitation under Section 73(10) runs from the date of this order, with the financial year 2024 25 treated as per Section 44; arrears including tax, penalty, interest and fees remain payable.
Proviso to sub rule (4) of Rule 22 of the CGST Rules permits an empowered officer to drop cancellation proceedings under Section 29(2)(c) if the person furnishes all pending returns and makes full payment of tax, interest and late fee, and to pass Form GST REG 20; restoration follows on compliance. The petitioner may apply for restoration within two months and the authority must consider and, if requirements are met, restore registration expeditiously. Computation of limitation under Section 73(10) runs from the date of this order, with the financial year 2024 25 treated as per Section 44; arrears including tax, penalty, interest and fees remain payable.
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