Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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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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