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Income Tax - Highlights / Catch Notes

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TP Adjustment - Period of limitation u/s 153(2A) - Scope of ...


Amendment to Income Tax Act Section 153(2A) Not Retrospective; Actions Beyond Limitation Period Deemed Unsustainable.

October 18, 2023

Case Laws     Income Tax     HC

TP Adjustment - Period of limitation u/s 153(2A) - Scope of amendment w.e.f. 1.4.2016 - retrospective effect - Legislative intention - the proceedings drawn, admittedly being beyond a period that is prescribed under sub-section (2A) of Section 153 and the consequential orders passed are all beyond the period of limitation prescribed under sub-section (2A) of Section 153. Hence, the same being not sustainable - HC

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