https://www.taxtmi.com/caselaws?id=795932 Reassessment initiated after four years following an assessment under section 143(3) is invalid where the taxpayer fully disclosed the subsidy transaction and the recorded reasons show neither failure of full and true disclosure nor fresh tangible material; reopening on the same material constitutes a change of opinion. A recurring subsidy from an associated enterprise that directly compensates unabsorbed distribution costs under a distribution agreement forms operating income where it is linked to annual performance, routinely received and recorded as operating revenue. It must therefore be included in transactional net margin method benchmarking of distribution transactions, eliminating the related transfer-pricing adjustment. en-us Mon, 27 Jul 2026 00:00:00 +0530 Wed, 29 Jul 2026 08:21:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795932 Reassessment initiated after four years following an assessment under section 143(3) is invalid where the taxpayer fully disclosed the subsidy transaction and the recorded reasons show neither failure of full and true disclosure nor fresh tangible material; reopening on the same material constitutes a change of opinion. A recurring subsidy from an associated enterprise that directly compensates unabsorbed distribution costs under a distribution agreement forms operating income where it is linked to annual performance, routinely received and recorded as operating revenue. It must therefore be included in transactional net margin method benchmarking of distribution transactions, eliminating the related transfer-pricing adjustment. Case-Laws Income Tax Mon, 27 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795932