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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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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