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...
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
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