Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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