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...
A pending appeal abated because the appellant company had been ordered into liquidation and no application for continuance was filed by the official liquidator under Rule 22 of the CESTAT Procedure Rules. The Tribunal applied Rule 22, which bars continuation of an appeal by a wound-up company unless the liquidator seeks to carry it on, and relied on Ghanshyam Mishra to confirm that the proceedings did not survive. The miscellaneous application was disposed of, and the delay in filing it was condoned.
A pending appeal abated because the appellant company had been ordered into liquidation and no application for continuance was filed by the official liquidator under Rule 22 of the CESTAT Procedure Rules. The Tribunal applied Rule 22, which bars continuation of an appeal by a wound-up company unless the liquidator seeks to carry it on, and relied on Ghanshyam Mishra to confirm that the proceedings did not survive. The miscellaneous application was disposed of, and the delay in filing it was condoned.
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