Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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