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...
Parallel Central GST adjudication could not be sustained where the same suppliers, the same alleged fake or non-existent status, and the same ITC disallowance for the same periods had already been adjudicated by the State GST Authority. Applying the principle against overlapping jurisdiction and duplicate proceedings on the same subject matter, the Court held that the later Central adjudication was unsustainable and set it aside. The Court declined to examine other issues and disposed of the connected applications accordingly.
Parallel Central GST adjudication could not be sustained where the same suppliers, the same alleged fake or non-existent status, and the same ITC disallowance for the same periods had already been adjudicated by the State GST Authority. Applying the principle against overlapping jurisdiction and duplicate proceedings on the same subject matter, the Court held that the later Central adjudication was unsustainable and set it aside. The Court declined to examine other issues and disposed of the connected applications accordingly.
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