Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO timelines. The changes directly impact ongoing appeals, rectification, revision, and reassessment proceedings, altering litigation strategy for taxpayers and authorities alike.
Analysis of the Rajeev Bansal Supreme Court ruling on reassessment approvals, clarifying complexities in Section 151 and its impact on assessing authorities.
Explore why foreign exchange gains/losses, particularly on revenue items, should be excluded from Profit Level Indicator (PLI) calculations in Transfer Pricing, challenging current judicial precedence and OECD guidelines.