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...
Interlocutory relief can be merged into and overtaken by a subsequent comprehensive supervisory order; where a final common order restructures management, orders a forensic audit and appoints an Independent Administrator under statutory management powers, earlier interim directions become part of that larger regime and an appeal against the interim step may be rendered infructuous. Maintainability objections had to be raised before the adjudicating authority; petitioner eligibility was satisfied by admitted shareholding above the statutory threshold. Any disputes over SPA clauses or receivables must now be addressed within the framework of the common order or upon the forensic audit report.
Interlocutory relief can be merged into and overtaken by a subsequent comprehensive supervisory order; where a final common order restructures management, orders a forensic audit and appoints an Independent Administrator under statutory management powers, earlier interim directions become part of that larger regime and an appeal against the interim step may be rendered infructuous. Maintainability objections had to be raised before the adjudicating authority; petitioner eligibility was satisfied by admitted shareholding above the statutory threshold. Any disputes over SPA clauses or receivables must now be addressed within the framework of the common order or upon the forensic audit report.
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