Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The HC quashed reassessment proceedings under s.147 initiated after four years on multiple grounds. The proceedings lacked jurisdiction as the reasons for reopening failed to specify any non-disclosure of material facts by the assessee as required by the first proviso to s.147. The Court noted discrepancies between reasons in the draft assessment order and those annexed to the reply affidavit. Additionally, the "guarantee fees" issue was already pending before the Tribunal, invoking the third proviso to s.147 which bars reassessment on matters under appellate consideration. The Court emphasized that since the issue had been examined and added in the original assessment, there was no income that had "escaped assessment," rendering the proceedings jurisdictionally defective.
The HC quashed reassessment proceedings under s.147 initiated after four years on multiple grounds. The proceedings lacked jurisdiction as the reasons for reopening failed to specify any non-disclosure of material facts by the assessee as required by the first proviso to s.147. The Court noted discrepancies between reasons in the draft assessment order and those annexed to the reply affidavit. Additionally, the "guarantee fees" issue was already pending before the Tribunal, invoking the third proviso to s.147 which bars reassessment on matters under appellate consideration. The Court emphasized that since the issue had been examined and added in the original assessment, there was no income that had "escaped assessment," rendering the proceedings jurisdictionally defective.
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