Notice U/s. 148 unsustainable Once Arm’s Length Price Procedure Followed

Advocate Akhilesh Kumar Sah Honda Motor Co. Ltd. Case: Where The Reassessment Is Based Only On The Allegation That The Appellant Has PE In India, The Notice Under Section 148 Cannot Sustain Once Arm’s Length Price Procedure Has Been Followed. Recently, in Honda Motor Co. Ltd. vs. DCIT [ITA Nos. 6018 & 6019/Del/2015 AYs: 2005-06 & 2006-07, decided on 13.12.2018], appeals had been filed by assessee against the final assessment order dated 31/08/15 passed by DCIT, International Taxation, Circle Noida, under section 147 read with 143(3)/144C(5) of the Income Tax Act, 1961 (for short ‘...