Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
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Section 152(3) preserves the pre-amendment reassessment regime for searches initiated from 1 April 2021 to 1 September 2024. Where information concerning an assessee arose from a third-party search within that transitional period, the former framework, including the relevant Explanation to section 148, remained applicable despite its omission. A direct reassessment notice under section 148 could therefore be issued without a prior notice under section 148A(b). The jurisdictional objection failed; the assessee could pursue the statutory appeal on the additions but could not reopen that jurisdictional issue.
Section 152(3) preserves the pre-amendment reassessment regime for searches initiated from 1 April 2021 to 1 September 2024. Where information concerning an assessee arose from a third-party search within that transitional period, the former framework, including the relevant Explanation to section 148, remained applicable despite its omission. A direct reassessment notice under section 148 could therefore be issued without a prior notice under section 148A(b). The jurisdictional objection failed; the assessee could pursue the statutory appeal on the additions but could not reopen that jurisdictional issue.
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