Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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