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...
HC ruled that time limits under Section 144C(13) for completing assessments following DRP directions are mandatory, not directory. The AO must pass orders within one month from the end of the month in which DRP directions are received. This limitation period cannot be counted from when the Transfer Pricing Officer implements DRP directions. The assessment order dated February 27, 2015, was held time-barred as it exceeded statutory limits. The court emphasized that limitation laws provide certainty and finality to tax proceedings, preventing indefinite litigation exposure. Following precedent in Vodafone Idea Limited, the court affirmed the mandatory nature of Section 144C(13) timelines and ruled in the assessee's favor, stressing strict adherence to prescribed time limits.
HC ruled that time limits under Section 144C(13) for completing assessments following DRP directions are mandatory, not directory. The AO must pass orders within one month from the end of the month in which DRP directions are received. This limitation period cannot be counted from when the Transfer Pricing Officer implements DRP directions. The assessment order dated February 27, 2015, was held time-barred as it exceeded statutory limits. The court emphasized that limitation laws provide certainty and finality to tax proceedings, preventing indefinite litigation exposure. Following precedent in Vodafone Idea Limited, the court affirmed the mandatory nature of Section 144C(13) timelines and ruled in the assessee's favor, stressing strict adherence to prescribed time limits.
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