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 ITAT held the reassessment order u/s 147/143(3) void ab initio due to jurisdictional defects. The notice was dispatched on 01.04.2014, rendering it time-barred beyond the 4-year limitation period. The tribunal found the assessee had fully disclosed material facts during original assessment proceedings, and the AO had already scrutinized all relevant information. Relying on SC precedent in Kelvinator case, the tribunal emphasized that reopening assessment cannot be a mere change of opinion. The AO's attempt to review was deemed an abuse of power, with the tribunal ultimately deciding in favor of the assessee.
The ITAT held the reassessment order u/s 147/143(3) void ab initio due to jurisdictional defects. The notice was dispatched on 01.04.2014, rendering it time-barred beyond the 4-year limitation period. The tribunal found the assessee had fully disclosed material facts during original assessment proceedings, and the AO had already scrutinized all relevant information. Relying on SC precedent in Kelvinator case, the tribunal emphasized that reopening assessment cannot be a mere change of opinion. The AO's attempt to review was deemed an abuse of power, with the tribunal ultimately deciding in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
