Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The assessment order was prima facie passed within the period of limitation on 30.09.2021, as evidenced by the presumption of validity and the email and physical dispatch to the petitioner. However, the petitioner's explanation dated 29.09.2021 was not considered, and the assessment appeared to be completed hurriedly to avoid limitation. To balance the interests, the High Court set aside the impugned assessment order and remitted the case to the respondents to pass orders on merits within six months, without finding fault on either party regarding the limitation issue.
The assessment order was prima facie passed within the period of limitation on 30.09.2021, as evidenced by the presumption of validity and the email and physical dispatch to the petitioner. However, the petitioner's explanation dated 29.09.2021 was not considered, and the assessment appeared to be completed hurriedly to avoid limitation. To balance the interests, the High Court set aside the impugned assessment order and remitted the case to the respondents to pass orders on merits within six months, without finding fault on either party regarding the limitation issue.
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