Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Electronic uploading of Dispute Resolution Panel directions on the ITBA portal constitutes receipt in faceless assessment proceedings for calculating the period for a final assessment under section 144C(13). A subsequent physical or manual receipt by the Assessing Officer does not extend that limitation. Directions uploaded on 30 December 2025 made the final assessment completed on 19 February 2026 time-barred; it was treated as null and void, while the remaining grounds were left open.
Electronic uploading of Dispute Resolution Panel directions on the ITBA portal constitutes receipt in faceless assessment proceedings for calculating the period for a final assessment under section 144C(13). A subsequent physical or manual receipt by the Assessing Officer does not extend that limitation. Directions uploaded on 30 December 2025 made the final assessment completed on 19 February 2026 time-barred; it was treated as null and void, while the remaining grounds were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
