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...
The Appellate Tribunal considered the issue of time limit for issuance of Transfer Pricing (TP) Order u/s 92CA(3A). Referring to a case law, it was held that the TP order passed on 01.11.2019 was barred by limitation. The TP adjustment became non-est due to the time limitation, making the assessee ineligible u/s 144C(15)(b). Consequently, Section 144C machinery provisions did not apply. The assessment should have been completed within 33 months from the end of the assessment year. Any order passed beyond the statutory time limit was deemed invalid. As a result, corporate additions in the assessment order were not sustainable, leading to the appeal being allowed on legal grounds.
The Appellate Tribunal considered the issue of time limit for issuance of Transfer Pricing (TP) Order u/s 92CA(3A). Referring to a case law, it was held that the TP order passed on 01.11.2019 was barred by limitation. The TP adjustment became non-est due to the time limitation, making the assessee ineligible u/s 144C(15)(b). Consequently, Section 144C machinery provisions did not apply. The assessment should have been completed within 33 months from the end of the assessment year. Any order passed beyond the statutory time limit was deemed invalid. As a result, corporate additions in the assessment order were not sustainable, leading to the appeal being allowed on legal grounds.
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