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 signed assessment order is mandatory under the CGST framework, and absence of the assessing officer's signature means the order is not validly served under Rule 26(3). The court also treated non-mention of a DIN in GST proceedings as affecting the validity of the proceeding. On that basis, the impugned assessment order was set aside, and delay in filing the writ petition was held immaterial because there was no service of the unsigned order. Liberty was granted to complete a fresh assessment after issuing notice and passing a duly signed order containing a DIN, with the intervening period excluded for limitation.
A signed assessment order is mandatory under the CGST framework, and absence of the assessing officer's signature means the order is not validly served under Rule 26(3). The court also treated non-mention of a DIN in GST proceedings as affecting the validity of the proceeding. On that basis, the impugned assessment order was set aside, and delay in filing the writ petition was held immaterial because there was no service of the unsigned order. Liberty was granted to complete a fresh assessment after issuing notice and passing a duly signed order containing a DIN, with the intervening period excluded for limitation.
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