Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
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The ITAT Delhi considered the validity of a re-assessment order where no notice u/s 148 was served on the assessee. The notice u/s 148 was issued through the ITBA portal but sent to the wrong email ID. The tribunal held that the notice generated on 30.03.2021 was not served on the assessee as the email ID did not belong to them. The limitation for issuing the notice would have ended on 30.03.2020, extended to 31.03.2021 due to Covid-19. The AO issued the notice just one day before the extended deadline, but the revenue failed to prove its service. The decision favored the assessee due to the lack of proper service of the notice.
The ITAT Delhi considered the validity of a re-assessment order where no notice u/s 148 was served on the assessee. The notice u/s 148 was issued through the ITBA portal but sent to the wrong email ID. The tribunal held that the notice generated on 30.03.2021 was not served on the assessee as the email ID did not belong to them. The limitation for issuing the notice would have ended on 30.03.2020, extended to 31.03.2021 due to Covid-19. The AO issued the notice just one day before the extended deadline, but the revenue failed to prove its service. The decision favored the assessee due to the lack of proper service of the notice.
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