Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Validity of order u/s 92CA (3) on the ground of limitation as contemplated u/s 153 - As the order of the Ld. TPO is barred by limitation, there is no variation to the income of the assessee pursuance to the reference made the Ld. TPO. Accordingly, assessee does not qualify to be an eligible assessee u/s 144C(15)(b). Thus, the moment the order of the TPO is quashed the assessee ceases to be an ‘eligible assessee’. Therefore, in that circumstances the time limit for completion of the assessment reverts back to 21 months. - AT
Validity of order u/s 92CA (3) on the ground of limitation as contemplated u/s 153 - As the order of the Ld. TPO is barred by limitation, there is no variation to the income of the assessee pursuance to the reference made the Ld. TPO. Accordingly, assessee does not qualify to be an eligible assessee u/s 144C(15)(b). Thus, the moment the order of the TPO is quashed the assessee ceases to be an ‘eligible assessee’. Therefore, in that circumstances the time limit for completion of the assessment reverts back to 21 months. - AT
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