Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Electronic dispatch through the ITBA portal determines the issuance date of a reassessment notice where transmission occurs after the statutory transition to the substituted reassessment procedure. A notice dated and digitally signed before 1 April 2021 but triggered and delivered electronically on that date is treated as issued on 1 April 2021, because the Department controlled the transmission delay. Such a notice cannot proceed directly under the earlier reassessment process; it must be treated as a show-cause notice under Section 148A(b), accompanied by the relied-upon information and material, with an opportunity to object before an order under Section 148A(d). Completed reassessment proceedings and consequential notices are therefore liable to be quashed, subject to fresh proceedings and statutory defences.
Electronic dispatch through the ITBA portal determines the issuance date of a reassessment notice where transmission occurs after the statutory transition to the substituted reassessment procedure. A notice dated and digitally signed before 1 April 2021 but triggered and delivered electronically on that date is treated as issued on 1 April 2021, because the Department controlled the transmission delay. Such a notice cannot proceed directly under the earlier reassessment process; it must be treated as a show-cause notice under Section 148A(b), accompanied by the relied-upon information and material, with an opportunity to object before an order under Section 148A(d). Completed reassessment proceedings and consequential notices are therefore liable to be quashed, subject to fresh proceedings and statutory defences.
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