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 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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