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...
High Court found the petitioner's statutory replies to Form GST DRC-01 notices inadequate, holding that mere production of voluminous documents does not negate alleged excess input tax claims. The Court required tabulation and reconciliation of bank statement entries with monthly GSTR-3B returns and annual GSTR-9/9C filings, and granted one opportunity for a clarified reply. Matters were remitted for fresh adjudication on merits, conditioned on the petitioner making a pre-deposit of Rs. 35,00,000 from its Electronic Cash Register within 30 days; bank attachment will be lifted on compliance and recovery proceedings are stayed during the compliance period.
High Court found the petitioner's statutory replies to Form GST DRC-01 notices inadequate, holding that mere production of voluminous documents does not negate alleged excess input tax claims. The Court required tabulation and reconciliation of bank statement entries with monthly GSTR-3B returns and annual GSTR-9/9C filings, and granted one opportunity for a clarified reply. Matters were remitted for fresh adjudication on merits, conditioned on the petitioner making a pre-deposit of Rs. 35,00,000 from its Electronic Cash Register within 30 days; bank attachment will be lifted on compliance and recovery proceedings are stayed during the compliance period.
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