29 results for “transfer pricing”+ Section 148(2)clear
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Appeals are dismissed
Bench: Shri Vijay Pal Rao & Shri B.M. Biyani
148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso