Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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Section 152(3) preserves the pre-amendment reassessment regime for searches initiated from 1 April 2021 to 1 September 2024. Where information concerning an assessee arose from a third-party search within that transitional period, the former framework, including the relevant Explanation to section 148, remained applicable despite its omission. A direct reassessment notice under section 148 could therefore be issued without a prior notice under section 148A(b). The jurisdictional objection failed; the assessee could pursue the statutory appeal on the additions but could not reopen that jurisdictional issue.
Section 152(3) preserves the pre-amendment reassessment regime for searches initiated from 1 April 2021 to 1 September 2024. Where information concerning an assessee arose from a third-party search within that transitional period, the former framework, including the relevant Explanation to section 148, remained applicable despite its omission. A direct reassessment notice under section 148 could therefore be issued without a prior notice under section 148A(b). The jurisdictional objection failed; the assessee could pursue the statutory appeal on the additions but could not reopen that jurisdictional issue.
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