Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The article addresses limitation for passing reassessment orders, holding that a judicial remand prescribing procedural timelines (supply of reasons, opportunity to file and dispose objections, and a brief bar before assessment) does not qualify as a "finding" or "direction" that triggers the extended limitation available where reassessment is made "in consequence of or to give effect to" a court finding or direction. Consequently, extended limitation is not attracted and ordinary limitation rules apply; after computing excluded periods from earlier writ proceedings and the additional statutory extension, the last date to pass reassessment had expired, rendering reassessment time barred and the writ allowed.
The article addresses limitation for passing reassessment orders, holding that a judicial remand prescribing procedural timelines (supply of reasons, opportunity to file and dispose objections, and a brief bar before assessment) does not qualify as a "finding" or "direction" that triggers the extended limitation available where reassessment is made "in consequence of or to give effect to" a court finding or direction. Consequently, extended limitation is not attracted and ordinary limitation rules apply; after computing excluded periods from earlier writ proceedings and the additional statutory extension, the last date to pass reassessment had expired, rendering reassessment time barred and the writ allowed.
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