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Assessments are governed by certain rules. Rule of consistency is one such rule.

The Delhi High Court in  [2023] 452 ITR 195 (Del) while referring to the observations of the Apex Court in  2019] 416 ITR 613 (SC) held that PRINCIPLE OF CONSISTENCY MUST BE FOLLOWED.

The matter related to the repeated question whether provision of services of market development (services of carrying out advertisement, marketing and business promotion i.e., AMP) are international transactions?

Under the law there is no reopening permissible for holding a change in opinion with reference to a given transaction/agreement for the same year.

With these 2-set rule parameters there is a possible hold under the law to reopening assessment in even subsequent or prior years if the material facts and circumstances remain unchanged no matter whether earlier assessment is framed u/s143(3) or 143(1). 

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