Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Section 92CD(3) requires an assessment for a year covered by a unilateral advance pricing agreement to be completed in accordance with that agreement when proceedings remain pending and a modified return is filed. For AY 2022-23, compliance with the UAPA and filing of the modified return meant that retaining the original transfer-pricing adjustment without considering the modified return was erroneous. The assessment must be completed after taking the modified return into account and applying the UAPA terms and conditions.
Section 92CD(3) requires an assessment for a year covered by a unilateral advance pricing agreement to be completed in accordance with that agreement when proceedings remain pending and a modified return is filed. For AY 2022-23, compliance with the UAPA and filing of the modified return meant that retaining the original transfer-pricing adjustment without considering the modified return was erroneous. The assessment must be completed after taking the modified return into account and applying the UAPA terms and conditions.
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