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...
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
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