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) limits blocking of the Electronic Credit Ledger to one year from the date of imposition, and any continuance beyond that period is contrary to the rule. Where the ledger blocking had continued after expiry of twelve months, the restriction was treated as having automatically ceased to operate. The Court declared the continued blocking illegal and directed the authorities to unblock the Electronic Credit Ledger forthwith.
Rule 86A(3) limits blocking of the Electronic Credit Ledger to one year from the date of imposition, and any continuance beyond that period is contrary to the rule. Where the ledger blocking had continued after expiry of twelve months, the restriction was treated as having automatically ceased to operate. The Court declared the continued blocking illegal and directed the authorities to unblock the Electronic Credit Ledger forthwith.
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