Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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The HC upheld the validity of a reassessment notice under Section 148 of the Income Tax Act, determining that the notice issued on 30.07.2022 was within the prescribed limitation period. The court excluded the period from 31.03.2021 to 02.06.2022 for limitation computation, based on Supreme Court precedents in Rajeev Bansal and Ashish Agarwal cases. The notice for Assessment Year 2015-2016 was deemed timely, as the original notice dated 31.03.2021 transformed into a valid notice under the new regime effective 01.04.2021, with the extended limitation period being applicable. Consequently, the court rejected all challenges to the reassessment proceedings.
The HC upheld the validity of a reassessment notice under Section 148 of the Income Tax Act, determining that the notice issued on 30.07.2022 was within the prescribed limitation period. The court excluded the period from 31.03.2021 to 02.06.2022 for limitation computation, based on Supreme Court precedents in Rajeev Bansal and Ashish Agarwal cases. The notice for Assessment Year 2015-2016 was deemed timely, as the original notice dated 31.03.2021 transformed into a valid notice under the new regime effective 01.04.2021, with the extended limitation period being applicable. Consequently, the court rejected all challenges to the reassessment proceedings.
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