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...
Judicial restraint applied where a writ petition sought mandamus to enforce statutory duties against alleged tax evasion based on disputed unaccounted cash transactions and supporting material. The Court held that the Single Judge was in declining to enter the merits and in refusing mandamus at that stage, because no illegality, irregularity, or jurisdictional error was shown in that approach. The writ jurisdiction was therefore not interfered with in appeal, and the writ appeal was dismissed as devoid of merit.
Judicial restraint applied where a writ petition sought mandamus to enforce statutory duties against alleged tax evasion based on disputed unaccounted cash transactions and supporting material. The Court held that the Single Judge was in declining to enter the merits and in refusing mandamus at that stage, because no illegality, irregularity, or jurisdictional error was shown in that approach. The writ jurisdiction was therefore not interfered with in appeal, and the writ appeal was dismissed as devoid of merit.
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