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...
Period of limitation - deeming a person to be an assessee-in-default - Non deduction of TDS - The Tribunal quashed the order dated 31.10.2019 issued u/s201(1) of the Income Tax Act, deeming it to be barred by limitation. The Tribunal followed its earlier decision, which held that amendments made to the statute with effect from 01/10/2014 are prospective, and concluded that the order should have been framed on or before 31.03.2015. As the order was framed on 31.10.2019, it was found to be time-barred. - AT
Period of limitation - deeming a person to be an assessee-in-default - Non deduction of TDS - The Tribunal quashed the order dated 31.10.2019 issued u/s201(1) of the Income Tax Act, deeming it to be barred by limitation. The Tribunal followed its earlier decision, which held that amendments made to the statute with effect from 01/10/2014 are prospective, and concluded that the order should have been framed on or before 31.03.2015. As the order was framed on 31.10.2019, it was found to be time-barred. - AT
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