Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
The Delhi High Court examined the validity of an order passed u/s 92CA and jurisdiction to pass an assessment order post-limitation period. The court held that once the Transfer Pricing Officer (TPO) passed an order in accordance with ITAT directions, the Assessing Officer (AO) was obligated to pass an assessment order within nine months. The court found that the AO's failure to do so rendered a subsequent reference to the TPO unwarranted. The court emphasized that the ITAT directions did not require a fresh reference, and the AO's actions were legally unjustified. The court concluded that the AO was barred from passing further assessment orders for the relevant assessment year, granting relief to the petitioner.
The Delhi High Court examined the validity of an order passed u/s 92CA and jurisdiction to pass an assessment order post-limitation period. The court held that once the Transfer Pricing Officer (TPO) passed an order in accordance with ITAT directions, the Assessing Officer (AO) was obligated to pass an assessment order within nine months. The court found that the AO's failure to do so rendered a subsequent reference to the TPO unwarranted. The court emphasized that the ITAT directions did not require a fresh reference, and the AO's actions were legally unjustified. The court concluded that the AO was barred from passing further assessment orders for the relevant assessment year, granting relief to the petitioner.
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