Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
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