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 final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.
The ITAT held that the final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.
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