Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Time limit for completion of assessment - scope of the term "Direction" u/s 153 - it must be express direction necessary for disposal of the case before the authority or Court. It must also be a direction which the authority or Court is empowered to give while deciding case before it. The expressions “findings” and “direction” in Section 153(3)(ii) must be accordingly confined. Section 153(3)(ii) is not a provision enlarging the jurisdiction of the authority or Court.
Time limit for completion of assessment - scope of the term "Direction" u/s 153 - it must be express direction necessary for disposal of the case before the authority or Court. It must also be a direction which the authority or Court is empowered to give while deciding case before it. The expressions “findings” and “direction” in Section 153(3)(ii) must be accordingly confined. Section 153(3)(ii) is not a provision enlarging the jurisdiction of the authority or Court.
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