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...
Blocking of the electronic credit ledger must be accompanied by written reasons and followed by opportunity to be heard; the respondent may issue a show cause notice after receipt of an investigation report and must communicate recorded reasons to the taxpayer. The taxpayer may file a reply with additional documentary evidence within one week of receiving the order; the respondent must then fix a personal hearing and decide either to revoke the blocking or issue a speaking order explaining rejection. Timelines: decision within two weeks after reply, or within three weeks if no reply is filed.
Blocking of the electronic credit ledger must be accompanied by written reasons and followed by opportunity to be heard; the respondent may issue a show cause notice after receipt of an investigation report and must communicate recorded reasons to the taxpayer. The taxpayer may file a reply with additional documentary evidence within one week of receiving the order; the respondent must then fix a personal hearing and decide either to revoke the blocking or issue a speaking order explaining rejection. Timelines: decision within two weeks after reply, or within three weeks if no reply is filed.
Note: It is a system-generated summary and is for quick reference only.
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