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...
Challenge to search and seizure under the CGST regime centred on whether cash qualifies as "goods" or as "documents or books or things" under Section 67; the court held the statutory definition of goods excludes money and reading "things" ejusdem generis with "documents" and "books" limits it to evidentiary items containing information. Cash may be seized only where specific notes or currency can be shown to have direct evidentiary value traceable to taxable transactions. On the facts, authorities failed to establish evidentiary necessity; the cash was ordered de-sealed and released, while broader validity of the search was left for further affidavit exchange and hearing with interim procedural restraints.
Challenge to search and seizure under the CGST regime centred on whether cash qualifies as "goods" or as "documents or books or things" under Section 67; the court held the statutory definition of goods excludes money and reading "things" ejusdem generis with "documents" and "books" limits it to evidentiary items containing information. Cash may be seized only where specific notes or currency can be shown to have direct evidentiary value traceable to taxable transactions. On the facts, authorities failed to establish evidentiary necessity; the cash was ordered de-sealed and released, while broader validity of the search was left for further affidavit exchange and hearing with interim procedural restraints.
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