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...
Statutory time bar in assessment law prevented reopening where no fresh assessment was passed within the period prescribed, and after an almost nine year lapse by Revenue following an ITAT order the HC held the assessment time barred and directed release of seized jewellery to the petitioner within six weeks. An intervenor's application seeking return of Stridhan was dismissed for lack of locus in this petition; the intervenor was permitted to pursue independent proceedings for any proprietary claim against the petitioner.
Statutory time bar in assessment law prevented reopening where no fresh assessment was passed within the period prescribed, and after an almost nine year lapse by Revenue following an ITAT order the HC held the assessment time barred and directed release of seized jewellery to the petitioner within six weeks. An intervenor's application seeking return of Stridhan was dismissed for lack of locus in this petition; the intervenor was permitted to pursue independent proceedings for any proprietary claim against the petitioner.
Note: It is a system-generated summary and is for quick reference only.