Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The amended reassessment regime requires exclusion of the period covered by deemed Section 148A proceedings, including the time taken to supply information and the assessee's response period, when computing limitation. Applying Ashish Agarwal, Rajeev Bansal and the limitation-extension principles recognised in TOLA/Cognizance, the Court treated the earlier notice as a deemed Section 148A(b) notice and found the Section 148A(d) order and consequential Section 148 notice issued on 30.07.2022 to be within time. On sanction, Section 151 as amended from 01.04.2021 permits approval by any authority named in clause (ii) after three years from the end of the assessment year, so approval by the Director General was sufficient.
The amended reassessment regime requires exclusion of the period covered by deemed Section 148A proceedings, including the time taken to supply information and the assessee's response period, when computing limitation. Applying Ashish Agarwal, Rajeev Bansal and the limitation-extension principles recognised in TOLA/Cognizance, the Court treated the earlier notice as a deemed Section 148A(b) notice and found the Section 148A(d) order and consequential Section 148 notice issued on 30.07.2022 to be within time. On sanction, Section 151 as amended from 01.04.2021 permits approval by any authority named in clause (ii) after three years from the end of the assessment year, so approval by the Director General was sufficient.
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