Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Under reassessment procedure, a scrutiny notice must be issued only after the taxpayer files a return in response to a reopening notice. Issuing the scrutiny notice before that return is filed makes the notice invalid and cannot cure the statutory defect. Without a valid scrutiny notice, the reassessment order is invalid. Reassessment orders founded on prematurely issued scrutiny notices are therefore liable to be set aside, and appeals challenging their invalidation fail where no further question of law arises.
Under reassessment procedure, a scrutiny notice must be issued only after the taxpayer files a return in response to a reopening notice. Issuing the scrutiny notice before that return is filed makes the notice invalid and cannot cure the statutory defect. Without a valid scrutiny notice, the reassessment order is invalid. Reassessment orders founded on prematurely issued scrutiny notices are therefore liable to be set aside, and appeals challenging their invalidation fail where no further question of law arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
