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...
The HC directed provisional release of seized imported goods at the interim stage of seizure memo proceedings, treating the request as confined to conditional release pending adjudication. Noting that similar writ petitions on identical facts had already been allowed on the same basis and that course had been left undisturbed by the Supreme Court, the Court ordered release subject to payment of the enhanced duty quantified by Customs, furnishing of a bank guarantee, and maintenance of transaction details for any onward sale. The order expressly preserved Customs' to proceed with adjudication independently and to decide the matter in accordance with law.
The HC directed provisional release of seized imported goods at the interim stage of seizure memo proceedings, treating the request as confined to conditional release pending adjudication. Noting that similar writ petitions on identical facts had already been allowed on the same basis and that course had been left undisturbed by the Supreme Court, the Court ordered release subject to payment of the enhanced duty quantified by Customs, furnishing of a bank guarantee, and maintenance of transaction details for any onward sale. The order expressly preserved Customs' to proceed with adjudication independently and to decide the matter in accordance with law.
Note: It is a system-generated summary and is for quick reference only.