Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
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