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 High Court quashed the Transfer Pricing Order (TPO) and consequent draft assessment order, holding them illegal and arbitrary. The TPO order was not digitally signed on the last date of limitation, i.e., 31.07.2021, or subsequently on 02.08.2021, despite confirmation from the respondent. It was physically/manually signed only on 12.08.2021 and furnished to the petitioner on 13.08.2021, well beyond the limitation period. The TPO order was also uploaded on the ITBA portal on 16.08.2021, after the limitation period. The mere generation of a DIN number did not cure the defects and omissions in the TPO order, which was barred by limitation. The Court held that digital/physical/manual signature on the TPO order is an essential and mandatory requirement, failing which it would be invalid and non-est in the eyes of law.
The High Court quashed the Transfer Pricing Order (TPO) and consequent draft assessment order, holding them illegal and arbitrary. The TPO order was not digitally signed on the last date of limitation, i.e., 31.07.2021, or subsequently on 02.08.2021, despite confirmation from the respondent. It was physically/manually signed only on 12.08.2021 and furnished to the petitioner on 13.08.2021, well beyond the limitation period. The TPO order was also uploaded on the ITBA portal on 16.08.2021, after the limitation period. The mere generation of a DIN number did not cure the defects and omissions in the TPO order, which was barred by limitation. The Court held that digital/physical/manual signature on the TPO order is an essential and mandatory requirement, failing which it would be invalid and non-est in the eyes of law.
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