Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
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