Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Electronic uploading of Dispute Resolution Panel directions on the ITBA portal constitutes valid and sufficient service for calculating the deadline for a final assessment under section 144C(13). Where directions were uploaded in October 2025, the final assessment had to be completed by the end of November 2025. Completion in December 2025 exceeded the prescribed limitation period, rendering the final assessment beyond jurisdiction and time-barred. Other grounds challenging the assessment remain open because limitation disposed of the matter.
Electronic uploading of Dispute Resolution Panel directions on the ITBA portal constitutes valid and sufficient service for calculating the deadline for a final assessment under section 144C(13). Where directions were uploaded in October 2025, the final assessment had to be completed by the end of November 2025. Completion in December 2025 exceeded the prescribed limitation period, rendering the final assessment beyond jurisdiction and time-barred. Other grounds challenging the assessment remain open because limitation disposed of the matter.
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