Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
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