Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Reassessment beyond four years was invalid where the original scrutiny had specifically examined disallowance of expenditure relating to exempt income and the assessee had provided relevant particulars. The revenue neither alleged failure to disclose fully and truly all material facts nor identified tangible material obtained after the original assessment showing income had escaped assessment. Reopening on re-examination of the same assessment record constituted a change of opinion. The High Court quashed the reassessment notice and consequential orders.
Reassessment beyond four years was invalid where the original scrutiny had specifically examined disallowance of expenditure relating to exempt income and the assessee had provided relevant particulars. The revenue neither alleged failure to disclose fully and truly all material facts nor identified tangible material obtained after the original assessment showing income had escaped assessment. Reopening on re-examination of the same assessment record constituted a change of opinion. The High Court quashed the reassessment notice and consequential orders.
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