Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Rectification u/s 154 - Period of limitation as per section 154(7) - In the present case, the order u/s. 143(3) was passed on 26/12/2011 and the financial year is FY 2010-11. The impugned order passed dated 30/11/2018 is certainly beyond four years thereof. Hence, in our considered opinion, the assessee succeeds on the additional ground. The rectification order passed u/s. 154 in this case is accordingly time barred and hence, the same is squashed as such - AT
Rectification u/s 154 - Period of limitation as per section 154(7) - In the present case, the order u/s. 143(3) was passed on 26/12/2011 and the financial year is FY 2010-11. The impugned order passed dated 30/11/2018 is certainly beyond four years thereof. Hence, in our considered opinion, the assessee succeeds on the additional ground. The rectification order passed u/s. 154 in this case is accordingly time barred and hence, the same is squashed as such - AT
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