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...
Amendment of pleadings and joinder of parties are permitted as a means to secure the right to adjudication on merits and to give effect to principles of natural justice where non-joinder caused dismissal; the tribunal's remedial power to allow rectification of the cause title is exercised in the interest of justice. The impugned dismissal is modified to permit the appellant to implead the necessary party, M/s. Al-Sami Food Exports Pvt Ltd, within two weeks, and respondents retain the right to file their counter after such amendment, preserving equitable balance and opportunity to decide the lis on merits.
Amendment of pleadings and joinder of parties are permitted as a means to secure the right to adjudication on merits and to give effect to principles of natural justice where non-joinder caused dismissal; the tribunal's remedial power to allow rectification of the cause title is exercised in the interest of justice. The impugned dismissal is modified to permit the appellant to implead the necessary party, M/s. Al-Sami Food Exports Pvt Ltd, within two weeks, and respondents retain the right to file their counter after such amendment, preserving equitable balance and opportunity to decide the lis on merits.
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