Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
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