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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Reopening of assessment - Though the return was filed by the assessee beyond the period of time frame as specified u/s. 139(5) of the Act, however, the same was filed much prior to the completion of assessment. Even if the said return was not considered by the AO for the purpose of assessment, the same could have been treated as return in response to the notice u/s. 148 as requested by the assessee.
Reopening of assessment - Though the return was filed by the assessee beyond the period of time frame as specified u/s. 139(5) of the Act, however, the same was filed much prior to the completion of assessment. Even if the said return was not considered by the AO for the purpose of assessment, the same could have been treated as return in response to the notice u/s. 148 as requested by the assessee.
Note: It is a system-generated summary and is for quick reference only.