Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
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