Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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