Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Electronic issuance of a reassessment notice occurs when it is dispatched through the ITBA system, not when digitally signed or generated. A notice recorded as issued on 1 April 2021 was therefore governed by the amended reassessment regime and required compliance with the pre-notice procedure under section 148A; its non-compliance rendered the notice invalid and vitiated the consequential reassessment order. Independently, where reassessment is initiated beyond three years from the end of the relevant assessment year, sanction must come from the specified higher authority under section 151(ii). Approval by the Principal Commissioner was incompetent, providing a separate ground to quash the notice.
Electronic issuance of a reassessment notice occurs when it is dispatched through the ITBA system, not when digitally signed or generated. A notice recorded as issued on 1 April 2021 was therefore governed by the amended reassessment regime and required compliance with the pre-notice procedure under section 148A; its non-compliance rendered the notice invalid and vitiated the consequential reassessment order. Independently, where reassessment is initiated beyond three years from the end of the relevant assessment year, sanction must come from the specified higher authority under section 151(ii). Approval by the Principal Commissioner was incompetent, providing a separate ground to quash the notice.
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