Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Impugned proceedings u/s 147 were held invalid as the notice u/s 148 was issued beyond the time limit prescribed u/s 149. The Tribunal interpreted the amended provisions along with the explanatory memorandum to mean that if the notice was barred by limitation under the erstwhile provisions, it cannot be issued even after the amendment. Consequently, the impugned notice and proceedings were quashed for being initiated beyond the prescribed time limit u/s 149, and the decision was in favor of the assessee.
Impugned proceedings u/s 147 were held invalid as the notice u/s 148 was issued beyond the time limit prescribed u/s 149. The Tribunal interpreted the amended provisions along with the explanatory memorandum to mean that if the notice was barred by limitation under the erstwhile provisions, it cannot be issued even after the amendment. Consequently, the impugned notice and proceedings were quashed for being initiated beyond the prescribed time limit u/s 149, and the decision was in favor of the assessee.
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