Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search operation in 2019, leading to an assessment order in 2023. The petitioner had appealed successfully against disallowances u/s 40(a)(ia) in the original assessment u/s 143(3). A subsequent notice u/s 148 related to a search in 2022, limited to AY 2014-15 per Section 149(1) proviso. Referring to Filatex India Ltd. and Ojjus Medicare Pvt. Ltd., the Court found AY 2013-14 outside the ten-year block period u/s 153C and 153A, making the notice unsustainable.
The High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search operation in 2019, leading to an assessment order in 2023. The petitioner had appealed successfully against disallowances u/s 40(a)(ia) in the original assessment u/s 143(3). A subsequent notice u/s 148 related to a search in 2022, limited to AY 2014-15 per Section 149(1) proviso. Referring to Filatex India Ltd. and Ojjus Medicare Pvt. Ltd., the Court found AY 2013-14 outside the ten-year block period u/s 153C and 153A, making the notice unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
