Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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