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...
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Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.
Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.
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TaxTMI 
TaxTMI 
of 4881 
