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 issue pertained to the validity of filing a revised return after the prescribed time limit. The High Court set aside the Tribunal's order, stating that after the revised return was time-barred, there was no provision to consider the appellant's claim. The Supreme Court held that the assessing officer cannot entertain any claim made by the assessee other than by following the provisions of the Income Tax Act. When a revised return was filed beyond the limitation period u/s 139(5), the assessing officer had no jurisdiction to consider the claim made therein. The Tribunal erred in directing the assessing officer to consider the appellant's claim in the time-barred revised return, as it should have exercised its power u/s 254 to consider the claim itself. The assessing officer's power is limited to considering claims made through valid revised returns filed within the prescribed time limit.
The issue pertained to the validity of filing a revised return after the prescribed time limit. The High Court set aside the Tribunal's order, stating that after the revised return was time-barred, there was no provision to consider the appellant's claim. The Supreme Court held that the assessing officer cannot entertain any claim made by the assessee other than by following the provisions of the Income Tax Act. When a revised return was filed beyond the limitation period u/s 139(5), the assessing officer had no jurisdiction to consider the claim made therein. The Tribunal erred in directing the assessing officer to consider the appellant's claim in the time-barred revised return, as it should have exercised its power u/s 254 to consider the claim itself. The assessing officer's power is limited to considering claims made through valid revised returns filed within the prescribed time limit.
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