Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not substitute recording satisfaction note by AO and handing over material for initiation of proceedings u/s 153C. No reference of asset representing escaped income, hence reopening for ten years u/s 153A not applicable. Notice issued beyond six years from end of AY 2014-15, beyond limitation period. HC allowed petition, set aside impugned notices u/s 148A(b) and 148, decided in favour of assessee.
A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not substitute recording satisfaction note by AO and handing over material for initiation of proceedings u/s 153C. No reference of asset representing escaped income, hence reopening for ten years u/s 153A not applicable. Notice issued beyond six years from end of AY 2014-15, beyond limitation period. HC allowed petition, set aside impugned notices u/s 148A(b) and 148, decided in favour of assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
