Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
The ITAT held that corrected TDS statements filed before the later amendment could not be treated as time-barred, because no specific filing limit then applied, and the amendment in the Finance (No. 2) Act, 2024 could not operate retrospectively. It also held that an appeal lay against the rectification order itself, so dismissal by the first appellate authority on limitation was unsustainable. On merits, the Tribunal held that fee under section 234E could not be levied through processing under section 200A for periods before 01.06.2015, because the enabling machinery came into force only from that date; the fee was deleted.
The ITAT held that corrected TDS statements filed before the later amendment could not be treated as time-barred, because no specific filing limit then applied, and the amendment in the Finance (No. 2) Act, 2024 could not operate retrospectively. It also held that an appeal lay against the rectification order itself, so dismissal by the first appellate authority on limitation was unsustainable. On merits, the Tribunal held that fee under section 234E could not be levied through processing under section 200A for periods before 01.06.2015, because the enabling machinery came into force only from that date; the fee was deleted.
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