Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Under the amended reassessment regime, a notice for reopening cannot survive if the case had already become time-barred under the old law. On the facts stated, the relevant assessment year remained within the earlier six-year period, and the time between the section 148A(b) notice and the assessee's reply had to be excluded for limitation; the section 148A(d) order and section 148 notice were therefore within time. The escaped income had not been part of the earlier scrutiny assessment, so the limitation challenge failed and the other objections were left open.
Under the amended reassessment regime, a notice for reopening cannot survive if the case had already become time-barred under the old law. On the facts stated, the relevant assessment year remained within the earlier six-year period, and the time between the section 148A(b) notice and the assessee's reply had to be excluded for limitation; the section 148A(d) order and section 148 notice were therefore within time. The escaped income had not been part of the earlier scrutiny assessment, so the limitation challenge failed and the other objections were left open.
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