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 held that the final assessment order passed by AO beyond the statutory time limit under Section 144C(13) was invalid. AO received DRP direction on 29.12.2015 and was mandated to complete assessment within one month from end of December 2015, i.e., by 31.01.2016. However, AO passed the assessment order on 18.02.2016, exceeding the prescribed timeline. The court ruled that Section 144C(13) provisions are mandatory, not discretionary, requiring AO to complete assessment within specified timeframe upon receiving DRP directions under Sub-Section (5). Since AO failed to comply with statutory timeline, the assessment order was deemed invalid. Appellant's appeal was allowed based on procedural non-compliance with mandatory statutory provisions.
HC held that the final assessment order passed by AO beyond the statutory time limit under Section 144C(13) was invalid. AO received DRP direction on 29.12.2015 and was mandated to complete assessment within one month from end of December 2015, i.e., by 31.01.2016. However, AO passed the assessment order on 18.02.2016, exceeding the prescribed timeline. The court ruled that Section 144C(13) provisions are mandatory, not discretionary, requiring AO to complete assessment within specified timeframe upon receiving DRP directions under Sub-Section (5). Since AO failed to comply with statutory timeline, the assessment order was deemed invalid. Appellant's appeal was allowed based on procedural non-compliance with mandatory statutory provisions.
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