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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT held that the Dispute Resolution Panel (DRP) lacks jurisdiction to direct the Transfer Pricing Officer or Assessing Officer in second-round proceedings after the case was set aside by the Tribunal, particularly when a final assessment order under section 143(3) read with section 144C(3) had already been passed. The tribunal determined that section 144C and the Income-tax (Dispute Resolution Panel) Rules, 2009 do not confer such powers on the DRP. Relying on Undercarriage and Tractor Parts (P.) Ltd., which established that DRP can only give directions in pending assessment proceedings, the ITAT ruled that both the transfer pricing order under section 92CA(3) and the final assessment order were void ab-initio and accordingly quashed them.
The ITAT held that the Dispute Resolution Panel (DRP) lacks jurisdiction to direct the Transfer Pricing Officer or Assessing Officer in second-round proceedings after the case was set aside by the Tribunal, particularly when a final assessment order under section 143(3) read with section 144C(3) had already been passed. The tribunal determined that section 144C and the Income-tax (Dispute Resolution Panel) Rules, 2009 do not confer such powers on the DRP. Relying on Undercarriage and Tractor Parts (P.) Ltd., which established that DRP can only give directions in pending assessment proceedings, the ITAT ruled that both the transfer pricing order under section 92CA(3) and the final assessment order were void ab-initio and accordingly quashed them.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
