Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
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