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...
Statute prescribes distinct computation for the six-year and ten-year limitation periods for reopening assessments under the search provisions; the six-year window is counted from the preceding year while the ten-year period is reckoned from the end of the assessment year relating to the previous year in which the search occurred, and therefore the ten-year span runs later than the six-year span. Applying that computation to a search dated 09.05.2024 yields AY 2025-26 as the first year and AY 2016-17 as the tenth year, rendering AY 2015-16 beyond the ten-year period and the notice to reopen that year untenable and quashed.
Statute prescribes distinct computation for the six-year and ten-year limitation periods for reopening assessments under the search provisions; the six-year window is counted from the preceding year while the ten-year period is reckoned from the end of the assessment year relating to the previous year in which the search occurred, and therefore the ten-year span runs later than the six-year span. Applying that computation to a search dated 09.05.2024 yields AY 2025-26 as the first year and AY 2016-17 as the tenth year, rendering AY 2015-16 beyond the ten-year period and the notice to reopen that year untenable and quashed.
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