Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Under the former reassessment framework, time allowed or extended for an assessee's reply to a Section 148A(b) show-cause notice is excluded when computing the Section 149 limitation period. A notice is not invalid merely because the response period runs beyond the original limitation deadline. After that exclusion, where the remaining time does not exceed seven days, the sixth proviso provides a seven-day terminal period for issuing the Section 148A(d) order and consequential Section 148 notice. The exclusion does not create an open-ended period. Limitation must therefore be computed through the complete chronology of response periods, adjournments, extensions, reply-stage closure, and issuance of both the order and notice.
Under the former reassessment framework, time allowed or extended for an assessee's reply to a Section 148A(b) show-cause notice is excluded when computing the Section 149 limitation period. A notice is not invalid merely because the response period runs beyond the original limitation deadline. After that exclusion, where the remaining time does not exceed seven days, the sixth proviso provides a seven-day terminal period for issuing the Section 148A(d) order and consequential Section 148 notice. The exclusion does not create an open-ended period. Limitation must therefore be computed through the complete chronology of response periods, adjournments, extensions, reply-stage closure, and issuance of both the order and notice.
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