Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Time-barred DRP objections leave no valid objections for consideration. The AO must complete the assessment under section 144C(4)(b) on the basis of the draft order within the prescribed period and cannot await the DRP's disposal of belated objections. Statutory limitation binds both the assessee and the Revenue. A final assessment issued after that period because of such delay is barred by limitation, void ab initio, and liable to be quashed; merits need not be considered.
Time-barred DRP objections leave no valid objections for consideration. The AO must complete the assessment under section 144C(4)(b) on the basis of the draft order within the prescribed period and cannot await the DRP's disposal of belated objections. Statutory limitation binds both the assessee and the Revenue. A final assessment issued after that period because of such delay is barred by limitation, void ab initio, and liable to be quashed; merits need not be considered.
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