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...
The article explains that the court preserved the petitioner's right to institute a statutory appeal, extended limitation for 30 days and granted a limited 30 day stay of the impugned detention and penalty order; if no appeal is filed the stay lapses. It directs prompt public auction of seized perishable goods with consignor permitted to participate and mandates retention of auction proceeds by the department, preferably in an interest bearing account, pending the appeal. It further authorises conditional release of the detained vehicle on payment and furnishing of a bond, all interim measures being subject to the appellate outcome.
The article explains that the court preserved the petitioner's right to institute a statutory appeal, extended limitation for 30 days and granted a limited 30 day stay of the impugned detention and penalty order; if no appeal is filed the stay lapses. It directs prompt public auction of seized perishable goods with consignor permitted to participate and mandates retention of auction proceeds by the department, preferably in an interest bearing account, pending the appeal. It further authorises conditional release of the detained vehicle on payment and furnishing of a bond, all interim measures being subject to the appellate outcome.
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