Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Reassessment notices under Section 148 must be issued within the applicable limitation period. The original six-year period expired on 31 March 2020, while the relevant extension notification covered only notices whose original limitation expired on 31 March 2021; it therefore did not extend time for a notice issued on 1 April 2021. Such notice was time-barred, requiring the consequential assessment orders to be set aside. Section 292BB addresses defects in service where an assessee participates in proceedings despite ineffective service; it cannot validate a reassessment notice issued after the statutory limitation period.
Reassessment notices under Section 148 must be issued within the applicable limitation period. The original six-year period expired on 31 March 2020, while the relevant extension notification covered only notices whose original limitation expired on 31 March 2021; it therefore did not extend time for a notice issued on 1 April 2021. Such notice was time-barred, requiring the consequential assessment orders to be set aside. Section 292BB addresses defects in service where an assessee participates in proceedings despite ineffective service; it cannot validate a reassessment notice issued after the statutory limitation period.
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