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...
Reliance on precedent by adjudicating authorities must be verified: the article identifies that reliance on non existent, incorrect or irrelevant judicial citations (apparently AI generated) breaches principles of natural justice and produces a procedural defect in reasoned orders; such unverified dependence indicates failure to apply independent judicial mind and can vitiate findings. It recommends prescribing parameters and directions to regulate how quasi judicial authorities rely on High Court and Supreme Court decisions, calls for institutional guidance (including Senior Standing Counsel assistance), and notes interim relief was granted pending formulation and final disposal.
Reliance on precedent by adjudicating authorities must be verified: the article identifies that reliance on non existent, incorrect or irrelevant judicial citations (apparently AI generated) breaches principles of natural justice and produces a procedural defect in reasoned orders; such unverified dependence indicates failure to apply independent judicial mind and can vitiate findings. It recommends prescribing parameters and directions to regulate how quasi judicial authorities rely on High Court and Supreme Court decisions, calls for institutional guidance (including Senior Standing Counsel assistance), and notes interim relief was granted pending formulation and final disposal.
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