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...
For assessment year 2015-16, a reassessment notice issued under section 148 on 15.04.2022 was held time-barred because it was issued after six years from the end of the assessment year. The Tribunal followed the jurisdictional High Court's view that, for assessment years beginning on or before 01.04.2021, the first proviso to section 149 preserves the earlier limitation bar and the amended ten-year reopening period cannot operate retrospectively to revive a barred case. It also held that the exclusion provisions for time spent in section 148A proceedings do not override that limitation bar. The reassessment was therefore quashed.
For assessment year 2015-16, a reassessment notice issued under section 148 on 15.04.2022 was held time-barred because it was issued after six years from the end of the assessment year. The Tribunal followed the jurisdictional High Court's view that, for assessment years beginning on or before 01.04.2021, the first proviso to section 149 preserves the earlier limitation bar and the amended ten-year reopening period cannot operate retrospectively to revive a barred case. It also held that the exclusion provisions for time spent in section 148A proceedings do not override that limitation bar. The reassessment was therefore quashed.
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