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...
Input tax credit mismatch between Form GSTR-3B and Form GSTR-2A had to be reconciled in accordance with Circular No. 183/15/2022-GST before adverse adjudication; where that prescribed procedure was not followed, the adjudication order and consequential demand were set aside and the matter was remitted for fresh consideration from the stage of reply to the show cause notice. The assessee was left free to raise all other contentions in the remanded proceedings.
Input tax credit mismatch between Form GSTR-3B and Form GSTR-2A had to be reconciled in accordance with Circular No. 183/15/2022-GST before adverse adjudication; where that prescribed procedure was not followed, the adjudication order and consequential demand were set aside and the matter was remitted for fresh consideration from the stage of reply to the show cause notice. The assessee was left free to raise all other contentions in the remanded proceedings.
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