Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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