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...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Post-1 April 2021 searches are deemed under Explanation 2(i) to...
Post-search reassessment: Statutorily deemed income-escape information requires section 148 proceedings instead of continued scrutiny assessment under the new framework.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Post-1 April 2021 searches are deemed under Explanation 2(i) to section 148 to provide information suggesting that income has escaped assessment. This statutory deeming requires reassessment proceedings under section 148 rather than continuation and completion of a scrutiny assessment under section 143(3). Completing a scrutiny assessment despite the prescribed procedure creates a jurisdictional defect, rendering the assessment invalid. The requirement concerns the mandatory procedural route following a qualifying search.
Post-1 April 2021 searches are deemed under Explanation 2(i) to section 148 to provide information suggesting that income has escaped assessment. This statutory deeming requires reassessment proceedings under section 148 rather than continuation and completion of a scrutiny assessment under section 143(3). Completing a scrutiny assessment despite the prescribed procedure creates a jurisdictional defect, rendering the assessment invalid. The requirement concerns the mandatory procedural route following a qualifying search.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
