Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Reassessment notices under Section 148 for AYs 2002-03 and 2005-06 were held time-barred as they were issued beyond two years from the end of the relevant assessment years; accordingly, the Revenue's challenge failed on limitation. For AYs 2006-07 and 2007-08, treating the assessee as a representative assessee/agent without issuing notice and passing an order under Section 163(2) was held to be non-compliance with a mandatory statutory condition; the breach could not be cured by relying on the assessee's conduct, rendering the assessments invalid and sustaining the Tribunal's view against the Revenue. - HC
Reassessment notices under Section 148 for AYs 2002-03 and 2005-06 were held time-barred as they were issued beyond two years from the end of the relevant assessment years; accordingly, the Revenue's challenge failed on limitation. For AYs 2006-07 and 2007-08, treating the assessee as a representative assessee/agent without issuing notice and passing an order under Section 163(2) was held to be non-compliance with a mandatory statutory condition; the breach could not be cured by relying on the assessee's conduct, rendering the assessments invalid and sustaining the Tribunal's view against the Revenue. - HC
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