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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Under the former reassessment framework, time allowed or extended for an assessee's reply to a Section 148A(b) show-cause notice is excluded when computing the Section 149 limitation period. A notice is not invalid merely because the response period runs beyond the original limitation deadline. After that exclusion, where the remaining time does not exceed seven days, the sixth proviso provides a seven-day terminal period for issuing the Section 148A(d) order and consequential Section 148 notice. The exclusion does not create an open-ended period. Limitation must therefore be computed through the complete chronology of response periods, adjournments, extensions, reply-stage closure, and issuance of both the order and notice.
Under the former reassessment framework, time allowed or extended for an assessee's reply to a Section 148A(b) show-cause notice is excluded when computing the Section 149 limitation period. A notice is not invalid merely because the response period runs beyond the original limitation deadline. After that exclusion, where the remaining time does not exceed seven days, the sixth proviso provides a seven-day terminal period for issuing the Section 148A(d) order and consequential Section 148 notice. The exclusion does not create an open-ended period. Limitation must therefore be computed through the complete chronology of response periods, adjournments, extensions, reply-stage closure, and issuance of both the order and notice.
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