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 considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
High Court considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
Note: It is a system-generated summary and is for quick reference only.