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 High Court addressed delay in filing a GST appeal and held that, although the Appellate Authority remains bound by the limitation under the CGST/RGST Act, the explanation showed circumstances beyond the petitioner's control. It found that denying adjudication on merits in such circumstances would cause grave prejudice, so the delay was condoned and the appellate remedy was directed to be entertained on merits. The challenge to the validity of the notifications was not pressed and was left open.
The High Court addressed delay in filing a GST appeal and held that, although the Appellate Authority remains bound by the limitation under the CGST/RGST Act, the explanation showed circumstances beyond the petitioner's control. It found that denying adjudication on merits in such circumstances would cause grave prejudice, so the delay was condoned and the appellate remedy was directed to be entertained on merits. The challenge to the validity of the notifications was not pressed and was left open.
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