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...
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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