Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
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