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...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Reassessment initiated after three years from the end of the relevant assessment year required approval from the authority specified in section 151(ii). The Finance Act 2023 proviso to section 151, effective from 1 April 2023, operated prospectively and could not be treated as retrospective merely as a clarification. Extensions or exclusions under section 149 could not be imported into section 151 to extend the three-year period. As sanction under section 151 is a jurisdictional condition precedent, approval by the Principal Commissioner instead of the specified competent authority rendered the notice, order under section 148A(d), and consequential reassessment proceedings void ab initio and liable to be quashed.
Reassessment initiated after three years from the end of the relevant assessment year required approval from the authority specified in section 151(ii). The Finance Act 2023 proviso to section 151, effective from 1 April 2023, operated prospectively and could not be treated as retrospective merely as a clarification. Extensions or exclusions under section 149 could not be imported into section 151 to extend the three-year period. As sanction under section 151 is a jurisdictional condition precedent, approval by the Principal Commissioner instead of the specified competent authority rendered the notice, order under section 148A(d), and consequential reassessment proceedings void ab initio and liable to be quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
