SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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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