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 High Court dealt with a partial rejection of a waiver claim linked to belated filing of GSTR-9 and noted the absence of a specific appellate remedy against the waiver order. As the petitioner had not appeared despite notice, the Court held that one further opportunity should be granted to file a reply and supporting documents before the same authority. It set aside the impugned order and remanded the matter for fresh consideration, leaving all factual and legal contentions open. No finding was rendered on the merits of the waiver claim under Rule 164(10), and the request was to be reconsidered in light of the clarifications in Circular No. 238/32/2024-GST.
The High Court dealt with a partial rejection of a waiver claim linked to belated filing of GSTR-9 and noted the absence of a specific appellate remedy against the waiver order. As the petitioner had not appeared despite notice, the Court held that one further opportunity should be granted to file a reply and supporting documents before the same authority. It set aside the impugned order and remanded the matter for fresh consideration, leaving all factual and legal contentions open. No finding was rendered on the merits of the waiver claim under Rule 164(10), and the request was to be reconsidered in light of the clarifications in Circular No. 238/32/2024-GST.
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