Tag Archives: International Tax

CBDT Instruction No. 01/2022 and Section 148 notice for AY 2015-16 issued within TOLA limitation are valid.

By | August 10, 2026

CBDT Instruction No. 01/2022 and Section 148 notice for AY 2015-16 issued within TOLA limitation are valid. Issue Whether CBDT Instruction No. 01/2022, issued to implement the Supreme Court judgment in Union of India v. Ashish Agarwal, is legally valid. Whether an order under Section 148A(d) and a reassessment notice under Section 148 issued on… Read More »

Assessing Officer Cannot Reject Registered Valuer’s Improvement Cost Report Without Referencing Valuation Officer

By | July 15, 2026

Assessing Officer Cannot Reject Registered Valuer’s Improvement Cost Report Without Referencing Valuation Officer Issue Whether the Assessing Officer is legally justified in completely rejecting a registered valuer’s report and treating the cost of property improvement as nil due to a lack of decades-old documentary evidence, without making a statutory reference to the Departmental Valuation Officer… Read More »

Digest of 700 judgements on Transfer Pricing, International Tax and Domestic Tax

By | July 11, 2016

Judgements on Transfer Pricing, International Tax and Domestic Tax Transfer Pricing – Page 2 International Tax – Page 42 Domestic Tax – Page 57 International transactions Cases 1 to 11 Permanent Establishment Cases 243 to 256 Income – Cases 321 to 330 Most Appropriate Method Royalty / Fees for technical services – Cases 257 to… Read More »