Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Explanation to amended section 147 permits an ongoing reassessment to be enlarged for any escaped-income issue subsequently noticed, without separate compliance with the section 148A procedure. Removal of "and also" from the substantive provision distinguishes prior interpretations of the unamended law. Its wording and context show legislative intent to expand rather than merely clarify reassessment scope. "Any issue" covers material obtained after commencement from sources outside the original proceedings, including search material. Authorities may use such material to enlarge a pending reassessment for the same assessment year, despite a separate search-assessment mechanism.
Explanation to amended section 147 permits an ongoing reassessment to be enlarged for any escaped-income issue subsequently noticed, without separate compliance with the section 148A procedure. Removal of "and also" from the substantive provision distinguishes prior interpretations of the unamended law. Its wording and context show legislative intent to expand rather than merely clarify reassessment scope. "Any issue" covers material obtained after commencement from sources outside the original proceedings, including search material. Authorities may use such material to enlarge a pending reassessment for the same assessment year, despite a separate search-assessment mechanism.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
