Reopening for lack of price transparency & requirement of price adjustment in ALP valid

HIGH COURT OF KARNATAKA Sysarris Software (P.) Ltd. versus Deputy Commissioner of Income-tax WRIT APPEAL NO. 3039 OF 2012 (T-IT) Date of pronouncement – 07.01.2013 JUDGMENT 1. This writ appeal by an assessee under the provisions of the Income Tax Act, 1961 [for short, the Act], which is a private limited company, is aggrieved by the reopening of the concluded assessment for the assessment year 2006-07 by issue of notice under Section 148 of the Act. 2. The assessee questioned this reopening before a learned Single Judge of this court by filing a writ petition on the premise ...