Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Departmental undertaking that originals of seized documents missing from custody will not be relied upon resolves the specific grievance; adjudication may proceed for the listed tax periods on other available materials while ensuring the assessee is afforded the statutory right to file replies and be heard under the TGST Act. The decision rests on the department's representation and the procedural requirement of fair opportunity of hearing; there is no adjudication on the substantive validity or content of the seized materials whose originals are absent.
Departmental undertaking that originals of seized documents missing from custody will not be relied upon resolves the specific grievance; adjudication may proceed for the listed tax periods on other available materials while ensuring the assessee is afforded the statutory right to file replies and be heard under the TGST Act. The decision rests on the department's representation and the procedural requirement of fair opportunity of hearing; there is no adjudication on the substantive validity or content of the seized materials whose originals are absent.
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