Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The HC held that the second notice issued u/s 148A(b) was a standalone notice, not a continuation of the first notice. The information on which the notices were based was completely different. As the second standalone notice was issued beyond the 3-year period stipulated u/s 149(1)(a) for reopening assessment where escaped income is less than Rs. 50 lakhs, it was barred by limitation. Consequently, the HC set aside the impugned order u/s 148A(d) and the notice u/s 148A(b), deciding in favor of the assessee.
The HC held that the second notice issued u/s 148A(b) was a standalone notice, not a continuation of the first notice. The information on which the notices were based was completely different. As the second standalone notice was issued beyond the 3-year period stipulated u/s 149(1)(a) for reopening assessment where escaped income is less than Rs. 50 lakhs, it was barred by limitation. Consequently, the HC set aside the impugned order u/s 148A(d) and the notice u/s 148A(b), deciding in favor of the assessee.
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