Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Notice issued for reopening assessment u/s 147 was beyond the limitation period stipulated in Section 149(1). The High Court, following Ojjus Medicare Pvt. Limited, clarified the manner of reckoning the six or ten-year period for reopening assessment prior to six years or before expiry of ten years from the relevant assessment year u/s 153C. The court held that the ten-year period is to be reckoned from the end of the assessment year relevant to the year in which the notice u/s 148 is issued. Consequently, the impugned notice for Assessment Year 2015-16 was set aside, restraining the respondent from proceeding with the reassessment proceedings.
Notice issued for reopening assessment u/s 147 was beyond the limitation period stipulated in Section 149(1). The High Court, following Ojjus Medicare Pvt. Limited, clarified the manner of reckoning the six or ten-year period for reopening assessment prior to six years or before expiry of ten years from the relevant assessment year u/s 153C. The court held that the ten-year period is to be reckoned from the end of the assessment year relevant to the year in which the notice u/s 148 is issued. Consequently, the impugned notice for Assessment Year 2015-16 was set aside, restraining the respondent from proceeding with the reassessment proceedings.
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