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...
Entitlement to reimbursement of differential GST under a government contract was not decided on merits. The Court accepted the respondents' position that a mere assertion of tax payment was insufficient and that supporting documents evidencing actual payment or deposit of GST were required. It directed the petitioner to furnish proof of GST payment and ordered the respondents to examine the reimbursement claim and pass a reasoned decision in accordance with law within the stipulated time. No final adjudication was made on the substantive right to reimbursement.
Entitlement to reimbursement of differential GST under a government contract was not decided on merits. The Court accepted the respondents' position that a mere assertion of tax payment was insufficient and that supporting documents evidencing actual payment or deposit of GST were required. It directed the petitioner to furnish proof of GST payment and ordered the respondents to examine the reimbursement claim and pass a reasoned decision in accordance with law within the stipulated time. No final adjudication was made on the substantive right to reimbursement.
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