Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
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TaxTMI 
TaxTMI 
of 4894 
