Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Validity of reopening of assessment - Time limit for issuing notice - The High Court observed that the proviso to Section 149 was analyzed, concluding that it applied to assessment years before the amendment and incorporated the pre-amended Section 151. However, it did not incorporate the entire pre-amended Section 151 by reference. - Considering the impact of TOLA, the Court found that it extended time limits but was irrelevant to the challenge in the writ petitions. - As the orders and notices lacked approval from the specified authority under clause (ii) of Section 151, they were deemed invalid.
Validity of reopening of assessment - Time limit for issuing notice - The High Court observed that the proviso to Section 149 was analyzed, concluding that it applied to assessment years before the amendment and incorporated the pre-amended Section 151. However, it did not incorporate the entire pre-amended Section 151 by reference. - Considering the impact of TOLA, the Court found that it extended time limits but was irrelevant to the challenge in the writ petitions. - As the orders and notices lacked approval from the specified authority under clause (ii) of Section 151, they were deemed invalid.
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