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...
On certiorari review of an order under Section 74 concerning alleged wrongful availment of input tax credit by misstatement and suppression, the court found that reasons were recorded and relevant factors considered and therefore declined to interfere absent any shown perversity or mala fides; the petitioner's request to waive or reduce the statutory pre deposit for filing a statutory appeal was refused for lack of extraordinary circumstances; the writ petition challenging the Section 74 order was dismissed, and the court's observations were treated as tentative and without prejudice to any appeal on merits.
On certiorari review of an order under Section 74 concerning alleged wrongful availment of input tax credit by misstatement and suppression, the court found that reasons were recorded and relevant factors considered and therefore declined to interfere absent any shown perversity or mala fides; the petitioner's request to waive or reduce the statutory pre deposit for filing a statutory appeal was refused for lack of extraordinary circumstances; the writ petition challenging the Section 74 order was dismissed, and the court's observations were treated as tentative and without prejudice to any appeal on merits.
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