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 HC held that the assessment orders dated 30.08.2022 and 01.09.2022 were issued beyond the permissible limitation period. As per Section 144C(13), the AO must complete proceedings within one month from the end of the month in which the DRP directions u/s 144C(5) are received. The HC ruled that when the DRP uploaded its directions on the portal on 30.06.2022, it amounted to 'despatch' u/s 13(2) of the IT Act, and the AO's 'receipt' occurred on the same date when the electronic record entered the department's computer resource. Thus, the limitation period began from 30.06.2022, not 05.07.2022 when the email was received, rendering the impugned orders time-barred.
The HC held that the assessment orders dated 30.08.2022 and 01.09.2022 were issued beyond the permissible limitation period. As per Section 144C(13), the AO must complete proceedings within one month from the end of the month in which the DRP directions u/s 144C(5) are received. The HC ruled that when the DRP uploaded its directions on the portal on 30.06.2022, it amounted to 'despatch' u/s 13(2) of the IT Act, and the AO's 'receipt' occurred on the same date when the electronic record entered the department's computer resource. Thus, the limitation period began from 30.06.2022, not 05.07.2022 when the email was received, rendering the impugned orders time-barred.
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