Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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The HC held that reassessment proceedings for Assessment Year 2015-16 were governed by the amended limitation regime under section 149 effective from 01.09.2024. A notice issued under section 148 beyond three years from the end of the relevant assessment year was without jurisdiction unless the conditions in section 149(1)(b) were satisfied. As no material showed that escaped income met the statutory threshold for invoking the extended period, the jurisdictional basis for reassessment failed. The show-cause notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were quashed.
The HC held that reassessment proceedings for Assessment Year 2015-16 were governed by the amended limitation regime under section 149 effective from 01.09.2024. A notice issued under section 148 beyond three years from the end of the relevant assessment year was without jurisdiction unless the conditions in section 149(1)(b) were satisfied. As no material showed that escaped income met the statutory threshold for invoking the extended period, the jurisdictional basis for reassessment failed. The show-cause notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were quashed.
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