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...
Time limit to pass assessment u/s. 92CA(3) - Transfer pricing adjustments - After thorough consideration of the statutory provisions and legal arguments presented by both parties, the Tribunal found merit in the assessee's contention. It observed that the TPO's order, along with the subsequent draft and final assessment orders, were passed beyond the prescribed time limit. Despite the Revenue's assertion that the time limit was discretionary, the Tribunal upheld the assessee's argument, emphasizing the mandatory nature of the prescribed time frame.
Time limit to pass assessment u/s. 92CA(3) - Transfer pricing adjustments - After thorough consideration of the statutory provisions and legal arguments presented by both parties, the Tribunal found merit in the assessee's contention. It observed that the TPO's order, along with the subsequent draft and final assessment orders, were passed beyond the prescribed time limit. Despite the Revenue's assertion that the time limit was discretionary, the Tribunal upheld the assessee's argument, emphasizing the mandatory nature of the prescribed time frame.
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