Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Compliance with Dispute Resolution Panel directions under section 144C is mandatory when issuing the final assessment order. The text explains that where the Transfer Pricing Officer has given effect to those directions within the applicable limitation period, the Assessing Officer cannot issue a final order repeating the draft assessment position without incorporating them. A corrigendum issued after limitation cannot retrospectively cure that statutory defect or supply required findings, and is beyond jurisdiction. The described Tribunal decision therefore quashed the defective final assessment order, while leaving other grounds open.
Compliance with Dispute Resolution Panel directions under section 144C is mandatory when issuing the final assessment order. The text explains that where the Transfer Pricing Officer has given effect to those directions within the applicable limitation period, the Assessing Officer cannot issue a final order repeating the draft assessment position without incorporating them. A corrigendum issued after limitation cannot retrospectively cure that statutory defect or supply required findings, and is beyond jurisdiction. The described Tribunal decision therefore quashed the defective final assessment order, while leaving other grounds open.
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