Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
For reassessment notices issued more than three years after the end of the relevant assessment year, section 151(ii) requires approval from the statutorily specified authority rather than the Principal Commissioner. The notes state that the later proviso to section 151, effective from 1 April 2023 and allowing exclusion of time permitted for a reply under section 148A(b), operates prospectively and does not validate an earlier notice. Approval by an incompetent authority is a jurisdictional defect, not a defect in form, authentication or communication curable under section 292BC. On that basis, the reassessment for AY 2018-19 was quashed, with other contentions left open.
For reassessment notices issued more than three years after the end of the relevant assessment year, section 151(ii) requires approval from the statutorily specified authority rather than the Principal Commissioner. The notes state that the later proviso to section 151, effective from 1 April 2023 and allowing exclusion of time permitted for a reply under section 148A(b), operates prospectively and does not validate an earlier notice. Approval by an incompetent authority is a jurisdictional defect, not a defect in form, authentication or communication curable under section 292BC. On that basis, the reassessment for AY 2018-19 was quashed, with other contentions left open.
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