Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
ITAT adjudicated a tax assessment dispute regarding time-barred order limitations. The tribunal determined that the Assessment Officer's (AO) final assessment order passed on 24.08.2022 was beyond statutory limitation under section 144C(13), referencing Madras HC precedent which emphasized that limitation periods cannot be manipulated through internal procedural variations. The tribunal held that since DRP directions were received on 30.06.2022 at 9:53 p.m., the subsequent assessment order exceeded permissible timelines. Consequently, the tribunal allowed the assessee's appeal, declaring the additions in the assessment order void ab initio and directing their deletion.
ITAT adjudicated a tax assessment dispute regarding time-barred order limitations. The tribunal determined that the Assessment Officer's (AO) final assessment order passed on 24.08.2022 was beyond statutory limitation under section 144C(13), referencing Madras HC precedent which emphasized that limitation periods cannot be manipulated through internal procedural variations. The tribunal held that since DRP directions were received on 30.06.2022 at 9:53 p.m., the subsequent assessment order exceeded permissible timelines. Consequently, the tribunal allowed the assessee's appeal, declaring the additions in the assessment order void ab initio and directing their deletion.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
