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    <title>2025 (5) TMI 1333 - DELHI HIGH COURT</title>
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    <description>Delhi HC held that reopening of assessment beyond limitation period was invalid. The case involved amounts paid by petitioner to its associated enterprises for services. The court found that payments were regularly made to overseas AEs for claimed services and had been subject matter of assessments in previous years with references to Transfer Pricing Officer for arm&#039;s length price determination. Since the alleged escaped income was not based on single occasion but regular payments previously assessed, the case did not fall within exception to Section 149(1A). Following precedent in L-1 Identity Solutions case, the petition was allowed and reopening notice was quashed.</description>
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    <pubDate>Fri, 02 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 1333 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=771061</link>
      <description>Delhi HC held that reopening of assessment beyond limitation period was invalid. The case involved amounts paid by petitioner to its associated enterprises for services. The court found that payments were regularly made to overseas AEs for claimed services and had been subject matter of assessments in previous years with references to Transfer Pricing Officer for arm&#039;s length price determination. Since the alleged escaped income was not based on single occasion but regular payments previously assessed, the case did not fall within exception to Section 149(1A). Following precedent in L-1 Identity Solutions case, the petition was allowed and reopening notice was quashed.</description>
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      <pubDate>Fri, 02 May 2025 00:00:00 +0530</pubDate>
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