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...
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Following a search under section 132, assessment of search-related escaped income must proceed through the special reassessment mechanism under section 148 rather than the general scrutiny-assessment route under section 143(3). Consequently, a regular assessment made under section 143(3) for the relevant post-search assessment was treated as unsustainable in law and quashed, rendering the remaining grounds academic. The principle limits recourse to ordinary scrutiny assessment where the prescribed search-linked reassessment framework applies.
Following a search under section 132, assessment of search-related escaped income must proceed through the special reassessment mechanism under section 148 rather than the general scrutiny-assessment route under section 143(3). Consequently, a regular assessment made under section 143(3) for the relevant post-search assessment was treated as unsustainable in law and quashed, rendering the remaining grounds academic. The principle limits recourse to ordinary scrutiny assessment where the prescribed search-linked reassessment framework applies.
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