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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
