Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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