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...
Writ jurisdiction was declined because an efficacious statutory appeal lay before the GST Appellate Tribunal, including on the question of limitation before the first appellate authority. The petition was also procedurally deficient as the petitioner failed to place the revocation-rejection order on record, preventing proper scrutiny. In view of the available alternate remedy and the incomplete record, the court dismissed the petition, while granting liberty to pursue the remedy available in law.
Writ jurisdiction was declined because an efficacious statutory appeal lay before the GST Appellate Tribunal, including on the question of limitation before the first appellate authority. The petition was also procedurally deficient as the petitioner failed to place the revocation-rejection order on record, preventing proper scrutiny. In view of the available alternate remedy and the incomplete record, the court dismissed the petition, while granting liberty to pursue the remedy available in law.
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