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Where a joint remand requires a transfer-pricing reference, the actual reference attracts the additional limitation period under section 153(4). A remand alone is not a deemed reference. If the draft assessment meets the section 153 deadline, sections 144C(12) and (13) govern the subsequent dispute resolution and final assessment periods; section 144C(13A) does not revive an expired draft deadline. Faceless assessment procedure requires communication of proposed prejudicial variations and an effective opportunity to respond before the draft assessment. Arm's length benchmarking under the other method requires comparable uncontrolled transaction prices; cost-based charges require scrutiny of cost pools and allocations. Tested-party selection depends on functions, assets, risks, relative complexity and reliable data. A voluntary section 14A disallowance requires separate consideration, while further disallowance is limited to exempt income. A computation cannot introduce additions unsupported by the assessment order.
Where a joint remand requires a transfer-pricing reference, the actual reference attracts the additional limitation period under section 153(4). A remand alone is not a deemed reference. If the draft assessment meets the section 153 deadline, sections 144C(12) and (13) govern the subsequent dispute resolution and final assessment periods; section 144C(13A) does not revive an expired draft deadline. Faceless assessment procedure requires communication of proposed prejudicial variations and an effective opportunity to respond before the draft assessment. Arm's length benchmarking under the other method requires comparable uncontrolled transaction prices; cost-based charges require scrutiny of cost pools and allocations. Tested-party selection depends on functions, assets, risks, relative complexity and reliable data. A voluntary section 14A disallowance requires separate consideration, while further disallowance is limited to exempt income. A computation cannot introduce additions unsupported by the assessment order.
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