Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Reopening an income-tax assessment for the identical bank-deposit transaction already investigated and finally adjudicated is impermissible where the subsequent authority relies on the same material; the doctrine Nemo debet bis vexari pro una et eadem causa bars subjecting the assessee to duplicate adjudication. The court reiterates that a notice under section 148 requires "reasons to believe" grounded in tangible material with a nexus to escaped income and cannot be based on mere suspicion or a change of opinion. The reassessment attempt was self conflicting and set aside; the writ petition was allowed, preventing a second assessment on the same subject matter.
Reopening an income-tax assessment for the identical bank-deposit transaction already investigated and finally adjudicated is impermissible where the subsequent authority relies on the same material; the doctrine Nemo debet bis vexari pro una et eadem causa bars subjecting the assessee to duplicate adjudication. The court reiterates that a notice under section 148 requires "reasons to believe" grounded in tangible material with a nexus to escaped income and cannot be based on mere suspicion or a change of opinion. The reassessment attempt was self conflicting and set aside; the writ petition was allowed, preventing a second assessment on the same subject matter.
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