Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Transfer Pricing Adjustments - Validity of the order passed u/s. 92CA(3) - period of limitation - 60 days have to be counted prior to the date of last date of limitation u/s 153. - The date for passing of ld. TPO’s order was on or before 31/10/3019, because the completion of assessment u/s. 153(1), i.e., 21 months from the end of the assessment year plus 12 months extension considering TP reference has been made was 31/12/2019 - The ITAT agreed with the assessee, holding that the transfer pricing order was indeed barred by limitation. The tribunal emphasized the need for adherence to prescribed timelines for the validity of such orders. Consequently, the transfer pricing order was quashed. - Therefore, the tribunal declared the final assessment order as void and barred by limitation.
Transfer Pricing Adjustments - Validity of the order passed u/s. 92CA(3) - period of limitation - 60 days have to be counted prior to the date of last date of limitation u/s 153. - The date for passing of ld. TPO’s order was on or before 31/10/3019, because the completion of assessment u/s. 153(1), i.e., 21 months from the end of the assessment year plus 12 months extension considering TP reference has been made was 31/12/2019 - The ITAT agreed with the assessee, holding that the transfer pricing order was indeed barred by limitation. The tribunal emphasized the need for adherence to prescribed timelines for the validity of such orders. Consequently, the transfer pricing order was quashed. - Therefore, the tribunal declared the final assessment order as void and barred by limitation.
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