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...
Rule 86A(3) of the CGST Rules, 2017 limits blocking of an electronic credit ledger to one year from the date of imposition, so the restriction ceased by operation of law once that period expired. The HC held that the petitioner was entitled to unblocking without a separate declaration, and rejected the Department's reliance on cancellation of registration or possible future proceedings to extend an expired restriction. The impugned blocking was set aside, while issues concerning ITC eligibility and any other proceedings were expressly left open.
Rule 86A(3) of the CGST Rules, 2017 limits blocking of an electronic credit ledger to one year from the date of imposition, so the restriction ceased by operation of law once that period expired. The HC held that the petitioner was entitled to unblocking without a separate declaration, and rejected the Department's reliance on cancellation of registration or possible future proceedings to extend an expired restriction. The impugned blocking was set aside, while issues concerning ITC eligibility and any other proceedings were expressly left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
