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...
Impleadment under Order 1 Rule 10 CPC was considered: applicant failed to show that the lis cannot be effectively decided in his absence, and submitted grounds lacked supporting documents or a distinct legally protectable interest directly affected by the narrow issue (alleged non-consideration of Section 65 in admission). The Resolution Professional had appeared, filed a response and is competent to represent the corporate debtor and obtain information from the suspended director under the insolvency code; consequently impleadment was rejected and the appeal will proceed without the applicant.
Impleadment under Order 1 Rule 10 CPC was considered: applicant failed to show that the lis cannot be effectively decided in his absence, and submitted grounds lacked supporting documents or a distinct legally protectable interest directly affected by the narrow issue (alleged non-consideration of Section 65 in admission). The Resolution Professional had appeared, filed a response and is competent to represent the corporate debtor and obtain information from the suspended director under the insolvency code; consequently impleadment was rejected and the appeal will proceed without the applicant.
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