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...
Shifting of registered office under Rule 30(9) was upheld where the petitioner's appeal challenged only grant of interest on pre- and intra CIRP dues and no stay of the adjudicating order was obtained; the court applied the principle that mere pendency of an appeal does not suspend compliance absent an appellate stay and noted prior tribunal clarification that pendency is not a ground to avoid statutory requirements. The High Court concluded the Regional Director lawfully permitted relocation, finding no prejudice shown by the petitioners and that the second proviso of sub rule (9) did not bar consideration in these facts.
Shifting of registered office under Rule 30(9) was upheld where the petitioner's appeal challenged only grant of interest on pre- and intra CIRP dues and no stay of the adjudicating order was obtained; the court applied the principle that mere pendency of an appeal does not suspend compliance absent an appellate stay and noted prior tribunal clarification that pendency is not a ground to avoid statutory requirements. The High Court concluded the Regional Director lawfully permitted relocation, finding no prejudice shown by the petitioners and that the second proviso of sub rule (9) did not bar consideration in these facts.
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