Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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