Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Section 11 of the Black Money Act required completion of assessment within two years from the end of the financial year in which notice under section 10(1) was issued, so a notice dated 10-04-2018 meant the assessment had to be completed by 31-03-2021 unless a valid exclusion applied. The exchange-of-information exclusion did not apply because the relevant FT & TR references had already been made and the information received before proceedings began. TOLA and Notification No. 113/2021 did not save the delay, as that notification extended time only for the Income-tax Act and the Benami Transactions Act. The assessment order passed on 17-02-2022 was therefore quashed as time-barred.
Section 11 of the Black Money Act required completion of assessment within two years from the end of the financial year in which notice under section 10(1) was issued, so a notice dated 10-04-2018 meant the assessment had to be completed by 31-03-2021 unless a valid exclusion applied. The exchange-of-information exclusion did not apply because the relevant FT & TR references had already been made and the information received before proceedings began. TOLA and Notification No. 113/2021 did not save the delay, as that notification extended time only for the Income-tax Act and the Benami Transactions Act. The assessment order passed on 17-02-2022 was therefore quashed as time-barred.
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