Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
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