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...
Validity of assessment order passed u/s 144C - period of limitation - The ITAT Delhi found the final assessment order dated 30.06.2022 to be barred by limitation. It was established that the directions from the DRP were uploaded to the ITBA portal on 07.04.2022, contrary to the claim of the AO that they were made known only on 02.05.2022. Accordingly, the AO was required to pass the final assessment order by 31.05.2022, making the actual order passed on 30.06.2022 out of time.
Validity of assessment order passed u/s 144C - period of limitation - The ITAT Delhi found the final assessment order dated 30.06.2022 to be barred by limitation. It was established that the directions from the DRP were uploaded to the ITBA portal on 07.04.2022, contrary to the claim of the AO that they were made known only on 02.05.2022. Accordingly, the AO was required to pass the final assessment order by 31.05.2022, making the actual order passed on 30.06.2022 out of time.
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