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...
HC considered whether an existing Prohibition Order and Seizure Order could continue after remand where no confiscation proposal under Section 67(2) had been issued. The court observed no de novo orders were passed post-remand and, because notices did not propose confiscation, held that continuation of prohibition or seizure could not be sustained. Consequently the impugned Prohibition and Seizure Orders were quashed and the writ petition allowed.
HC considered whether an existing Prohibition Order and Seizure Order could continue after remand where no confiscation proposal under Section 67(2) had been issued. The court observed no de novo orders were passed post-remand and, because notices did not propose confiscation, held that continuation of prohibition or seizure could not be sustained. Consequently the impugned Prohibition and Seizure Orders were quashed and the writ petition allowed.
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