Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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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