Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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