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 Registrar lacks power under the Registration Act to cancel already registered sale deeds; cancellation is a substantive remedy for civil adjudication and cannot be achieved by summary administrative orders except where fraud is manifest on the face of the record. Section 68(2) confers supervisory control over sub-registrars and rectification of registration records but does not authorize annulment of instruments. Administrative nullification during pending civil proceedings usurps the civil forum and was held impermissible; the writ was set aside and the intra-court appeal allowed. The court applied established SC precedent restricting registrar cancellation powers.
The Registrar lacks power under the Registration Act to cancel already registered sale deeds; cancellation is a substantive remedy for civil adjudication and cannot be achieved by summary administrative orders except where fraud is manifest on the face of the record. Section 68(2) confers supervisory control over sub-registrars and rectification of registration records but does not authorize annulment of instruments. Administrative nullification during pending civil proceedings usurps the civil forum and was held impermissible; the writ was set aside and the intra-court appeal allowed. The court applied established SC precedent restricting registrar cancellation powers.
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