Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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The High Court held that the notices issued u/s 148 for reassessment on or after April 1, 2021, are barred by limitation u/ss 148 and 149 of the Income Tax Act, 1961. The court endorsed the views of the Supreme Court's decision in Ashish Agarwal's case and the Delhi High Court's decision in Suman Jeet Agarwal's case. The court ruled that the amended provisions of Section 148A, introduced by the Finance Act, 2021, would govern the field for any reassessment notice issued on or after April 1, 2021, as the unamended provisions were valid only until March 31, 2021. The court held that the impugned notices in these writ petitions were barred by limitation since they were dispatched from the Income Tax Department's portal on or after April 1, 2021.
The High Court held that the notices issued u/s 148 for reassessment on or after April 1, 2021, are barred by limitation u/ss 148 and 149 of the Income Tax Act, 1961. The court endorsed the views of the Supreme Court's decision in Ashish Agarwal's case and the Delhi High Court's decision in Suman Jeet Agarwal's case. The court ruled that the amended provisions of Section 148A, introduced by the Finance Act, 2021, would govern the field for any reassessment notice issued on or after April 1, 2021, as the unamended provisions were valid only until March 31, 2021. The court held that the impugned notices in these writ petitions were barred by limitation since they were dispatched from the Income Tax Department's portal on or after April 1, 2021.
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