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...
Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.
Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.
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