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 of assessment under the reformed reassessment procedure is impermissible once an assessment order has been passed; the note explains that where prior proceedings under the old regime did not result in an assessment order, a fresh notice within the statutory limitation window may be issued in line with recent higher-court guidance, but once an assessment order exists there is no scope to issue a fresh reopening notice or reopen the assessment under the substituted procedure. The piece contrasts the pre-reform practice permitting returns after notice with the effect of the new regime and concludes finality of completed assessments.
Reopening of assessment under the reformed reassessment procedure is impermissible once an assessment order has been passed; the note explains that where prior proceedings under the old regime did not result in an assessment order, a fresh notice within the statutory limitation window may be issued in line with recent higher-court guidance, but once an assessment order exists there is no scope to issue a fresh reopening notice or reopen the assessment under the substituted procedure. The piece contrasts the pre-reform practice permitting returns after notice with the effect of the new regime and concludes finality of completed assessments.
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