https://www.taxtmi.com/caselaws?id=795932 Reassessment after four years of an assessment completed under section 143(3) is described as invalid where the taxpayer fully disclosed the subsidy transaction and the recorded reasons show neither fresh tangible material nor failure of full and true disclosure; reopening on the same material constitutes a change of opinion. The notes also state that a recurring associated-enterprise subsidy compensating unabsorbed distribution costs has a direct nexus with distribution activity and is operating income for transactional net margin method benchmarking. Accordingly, the subsidy forms part of aggregated distribution results and the related transfer-pricing adjustment is deleted. 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 after four years of an assessment completed under section 143(3) is described as invalid where the taxpayer fully disclosed the subsidy transaction and the recorded reasons show neither fresh tangible material nor failure of full and true disclosure; reopening on the same material constitutes a change of opinion. The notes also state that a recurring associated-enterprise subsidy compensating unabsorbed distribution costs has a direct nexus with distribution activity and is operating income for transactional net margin method benchmarking. Accordingly, the subsidy forms part of aggregated distribution results and the related transfer-pricing adjustment is deleted. Case-Laws Income Tax Mon, 27 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795932