Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
ITAT adjudicated a tax dispute regarding TDS non-deduction for external development charges. The tribunal examined the limitation period under Section 201(3) and found the assessment order dated 30.03.2021 for AY 2014-15 was beyond the prescribed time limit. Relying on precedent in a similar case involving an entertainment network company, the tribunal quashed the impugned order, accepting the assessee's argument that the order could not be passed after the statutory limitation period. The assessee's appeal was allowed, effectively setting aside the demand raised under Section 201(1) read with Section 201(1A).
ITAT adjudicated a tax dispute regarding TDS non-deduction for external development charges. The tribunal examined the limitation period under Section 201(3) and found the assessment order dated 30.03.2021 for AY 2014-15 was beyond the prescribed time limit. Relying on precedent in a similar case involving an entertainment network company, the tribunal quashed the impugned order, accepting the assessee's argument that the order could not be passed after the statutory limitation period. The assessee's appeal was allowed, effectively setting aside the demand raised under Section 201(1) read with Section 201(1A).
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