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...
Service of assessment order under the statutory notice procedure was deficient where the revenue admitted upload failures on the e filing portal and claimed postal service without producing tracking proof; the tribunal applied the procedural requirement of service under Section 282 and Rule 127 and, finding no credible proof that the assessment order, computation and demand notice were served in accordance with the rules, concluded that non service caused a miscarriage of justice and allowed the taxpayer's appeal.
Service of assessment order under the statutory notice procedure was deficient where the revenue admitted upload failures on the e filing portal and claimed postal service without producing tracking proof; the tribunal applied the procedural requirement of service under Section 282 and Rule 127 and, finding no credible proof that the assessment order, computation and demand notice were served in accordance with the rules, concluded that non service caused a miscarriage of justice and allowed the taxpayer's appeal.
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