Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT held that the Transfer Pricing Officer's order was barred by limitation as it was not passed within 60 days from the date of the final assessment order as required u/s 92CA(3A) read with Section 153/153B. The Transfer Pricing Officer was required to pass the order on or before 31.10.2019, which was 60 days prior to the expiry of the limitation period of 21 months from the end of the assessment year on 31.12.2019 as per Section 153. Since the Transfer Pricing Officer's order dated 01.11.2019 was barred by limitation, the final assessment order passed by the Assessing Officer on 26.02.2020 without the Transfer Pricing Officer's order also became barred by limitation.
The ITAT held that the Transfer Pricing Officer's order was barred by limitation as it was not passed within 60 days from the date of the final assessment order as required u/s 92CA(3A) read with Section 153/153B. The Transfer Pricing Officer was required to pass the order on or before 31.10.2019, which was 60 days prior to the expiry of the limitation period of 21 months from the end of the assessment year on 31.12.2019 as per Section 153. Since the Transfer Pricing Officer's order dated 01.11.2019 was barred by limitation, the final assessment order passed by the Assessing Officer on 26.02.2020 without the Transfer Pricing Officer's order also became barred by limitation.
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