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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
HC held that for reassessment proceedings under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment, not the search date. The ten-year block is calculated from the end of AY 2024-25, when the notice was issued on 30.03.2024. Consistent with prior judicial precedents, the court found the impugned notice barred by limitation and allowed the petition, setting aside the notice as time-barred.
HC held that for reassessment proceedings under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment, not the search date. The ten-year block is calculated from the end of AY 2024-25, when the notice was issued on 30.03.2024. Consistent with prior judicial precedents, the court found the impugned notice barred by limitation and allowed the petition, setting aside the notice as time-barred.
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