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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HC upheld the petition, declaring assessment notices for AY 2010-11 time-barred under Section 153(3). The Tribunal's order passed after 01 April 2019 extended the limitation period from 9 to 12 months. Calculating 12 months from the Tribunal's 21 October 2020 order revealed the jurisdictional authority expired on 21 October 2021. Consequently, the HC quashed the assessment notices dated 06 March 2023 and 19 March 2023 as legally impermissible, effectively invalidating any proposed transfer pricing adjustments beyond the prescribed statutory limitation.
HC upheld the petition, declaring assessment notices for AY 2010-11 time-barred under Section 153(3). The Tribunal's order passed after 01 April 2019 extended the limitation period from 9 to 12 months. Calculating 12 months from the Tribunal's 21 October 2020 order revealed the jurisdictional authority expired on 21 October 2021. Consequently, the HC quashed the assessment notices dated 06 March 2023 and 19 March 2023 as legally impermissible, effectively invalidating any proposed transfer pricing adjustments beyond the prescribed statutory limitation.
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