Reassessment power under section 147 allows reopening for income from assets located outside India and failures to report international transactions. Amendments clarify that the first proviso's limitation on reopening assessments does not apply where income relating to any asset located outside India chargeable to tax has escaped assessment; they add as reassessment triggers failure to furnish a transfer pricing report for international transactions and discovery of assets located outside India, and insert an explanation confirming applicability to assessment years beginning on or before 1 April 2012.
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Provisions expressly mentioned in the judgment/order text.
Reassessment power under section 147 allows reopening for income from assets located outside India and failures to report international transactions.
Amendments clarify that the first proviso's limitation on reopening assessments does not apply where income relating to any asset located outside India chargeable to tax has escaped assessment; they add as reassessment triggers failure to furnish a transfer pricing report for international transactions and discovery of assets located outside India, and insert an explanation confirming applicability to assessment years beginning on or before 1 April 2012.
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