Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Where additions rested entirely on seized material and statements from the search of a related person, the assessee, as an 'other person', had to be proceeded against under the special search regime in section 153C. The non-obstante clause in section 153C overrides sections 147 and 148, so the Assessing Officer could not bypass that machinery and reopen the assessment on the same search material. Because the section 153C procedure was not followed, the notice under section 148 and all consequential reassessment proceedings were without jurisdiction and were quashed for both years.
Where additions rested entirely on seized material and statements from the search of a related person, the assessee, as an 'other person', had to be proceeded against under the special search regime in section 153C. The non-obstante clause in section 153C overrides sections 147 and 148, so the Assessing Officer could not bypass that machinery and reopen the assessment on the same search material. Because the section 153C procedure was not followed, the notice under section 148 and all consequential reassessment proceedings were without jurisdiction and were quashed for both years.
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