Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
The Appellate Tribunal considered the validity of final assessment orders passed beyond the limit set by section 144C(13). It was held that the Assessing Officer (AO) must issue the final assessment order within one month of receiving directions from the DRP. In the case of AY 2017-18, the AO passed the final assessment order on 02.01.2023, which was after the prescribed time limit, making it barred by limitation. Similarly, for AY 2018-19, the AO's order on 30.12.2022 was also beyond the limit. Consequently, both orders were quashed as they violated section 144C(13), and the appeal of the assessee was allowed.
The Appellate Tribunal considered the validity of final assessment orders passed beyond the limit set by section 144C(13). It was held that the Assessing Officer (AO) must issue the final assessment order within one month of receiving directions from the DRP. In the case of AY 2017-18, the AO passed the final assessment order on 02.01.2023, which was after the prescribed time limit, making it barred by limitation. Similarly, for AY 2018-19, the AO's order on 30.12.2022 was also beyond the limit. Consequently, both orders were quashed as they violated section 144C(13), and the appeal of the assessee was allowed.
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