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 HC declined to entertain a writ petition challenging GST detention and release proceedings because the tax and penalty were paid after service of notice in Form GST MOV-07 and the goods were then released, with no contemporaneous protest shown. The Court treated the proceedings as concluded upon payment, held that the penalty order was appealable, and noted that no appeal had been filed within the prescribed period. It found no demonstrated violation of natural justice or jurisdictional error to justify bypassing the statutory appellate remedy, and dismissed the petition as devoid of merit.
A HC declined to entertain a writ petition challenging GST detention and release proceedings because the tax and penalty were paid after service of notice in Form GST MOV-07 and the goods were then released, with no contemporaneous protest shown. The Court treated the proceedings as concluded upon payment, held that the penalty order was appealable, and noted that no appeal had been filed within the prescribed period. It found no demonstrated violation of natural justice or jurisdictional error to justify bypassing the statutory appellate remedy, and dismissed the petition as devoid of merit.
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