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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The Tribunal upheld the validity of the assessment order. Despite the alleged violation of statutory procedure u/s 144B, the Tribunal found that the assessment proceedings were not time-barred. The Dispute Resolution Panel's (DRP) directions u/s 144C(5) were initially not visible to the Assessing Officer due to a software issue. However, the Revenue proved that the DRP order was received by the National Faceless Assessment Centre on 06.04.2022 and uploaded on 18.04.2022, after which the Assessing Officer received it. The final assessment order passed on 30.05.2022 was within the time limit prescribed u/s 144C(13) from the date of receipt of the DRP order. Relying on the Supreme Court's interpretation of "receipt" in CIT vs. Mohammed Meeran Shahul Hameed, the Tribunal held the assessment order legally valid and decided against the assessee.
The Tribunal upheld the validity of the assessment order. Despite the alleged violation of statutory procedure u/s 144B, the Tribunal found that the assessment proceedings were not time-barred. The Dispute Resolution Panel's (DRP) directions u/s 144C(5) were initially not visible to the Assessing Officer due to a software issue. However, the Revenue proved that the DRP order was received by the National Faceless Assessment Centre on 06.04.2022 and uploaded on 18.04.2022, after which the Assessing Officer received it. The final assessment order passed on 30.05.2022 was within the time limit prescribed u/s 144C(13) from the date of receipt of the DRP order. Relying on the Supreme Court's interpretation of "receipt" in CIT vs. Mohammed Meeran Shahul Hameed, the Tribunal held the assessment order legally valid and decided against the assessee.
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