Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Where a valid search under s.132 was conducted on the assessee, the assessee could not be treated as a "third party", and the special search assessment code under ss.153A-153D was held to override the general reassessment provision in s.147; accordingly, s.147 could not be invoked to bypass the statutory machinery and limitation applicable to a searched person, and the departmental objection was rejected. Although the search-year assessment (AY corresponding to the year of search) is not within the six preceding years under s.153A, the time limit under s.153B applies to both the six years and the year of search; since the assessment was completed beyond the prescribed outer limit, it was held time-barred and void ab initio, and the assessment was quashed. - ITAT
Where a valid search under s.132 was conducted on the assessee, the assessee could not be treated as a "third party", and the special search assessment code under ss.153A-153D was held to override the general reassessment provision in s.147; accordingly, s.147 could not be invoked to bypass the statutory machinery and limitation applicable to a searched person, and the departmental objection was rejected. Although the search-year assessment (AY corresponding to the year of search) is not within the six preceding years under s.153A, the time limit under s.153B applies to both the six years and the year of search; since the assessment was completed beyond the prescribed outer limit, it was held time-barred and void ab initio, and the assessment was quashed. - ITAT
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