AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
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