Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Section 153A's extended ten-year reassessment period is described as being computed differently from the six-year period. The six assessment years immediately precede the assessment year relevant to the search year, whereas the ten-year period runs from the end of that assessment year and includes the search assessment year as its first year. The note states that this interpretation also applies where seized material is received by the jurisdictional Assessing Officer under section 153C. On that computation, the reassessment notice for AY 2015-16 was treated as beyond the permissible period and quashed as time-barred.
Section 153A's extended ten-year reassessment period is described as being computed differently from the six-year period. The six assessment years immediately precede the assessment year relevant to the search year, whereas the ten-year period runs from the end of that assessment year and includes the search assessment year as its first year. The note states that this interpretation also applies where seized material is received by the jurisdictional Assessing Officer under section 153C. On that computation, the reassessment notice for AY 2015-16 was treated as beyond the permissible period and quashed as time-barred.
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