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...
For AY 2015-16, reassessment notices issued after expiry of the earlier six-year limitation could not be revived under the amended regime. The exclusion and extension in the fifth and sixth provisos were confined to computing limitation under the amended provision and did not dilute the absolute bar created by the first proviso where the notice had already become time-barred. A notice issued on 07/04/2022 was therefore beyond the surviving limitation and without jurisdiction, and the consequential reassessment was quashed.
For AY 2015-16, reassessment notices issued after expiry of the earlier six-year limitation could not be revived under the amended regime. The exclusion and extension in the fifth and sixth provisos were confined to computing limitation under the amended provision and did not dilute the absolute bar created by the first proviso where the notice had already become time-barred. A notice issued on 07/04/2022 was therefore beyond the surviving limitation and without jurisdiction, and the consequential reassessment was quashed.
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