Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
A notice under section 148 issued on 07.04.2022 for A.Y. 2015-16 was treated as time-barred because the first proviso to section 149(1) preserves the limitation applicable to pre-01.04.2021 assessment years. The six-year period under the unamended regime had expired on 31.03.2022, so the amended law could not revive a notice that was already barred. On that basis, the reassessment order founded on the invalid notice was also quashed, and the remaining grounds were left open.
A notice under section 148 issued on 07.04.2022 for A.Y. 2015-16 was treated as time-barred because the first proviso to section 149(1) preserves the limitation applicable to pre-01.04.2021 assessment years. The six-year period under the unamended regime had expired on 31.03.2022, so the amended law could not revive a notice that was already barred. On that basis, the reassessment order founded on the invalid notice was also quashed, and the remaining grounds were left open.
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