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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The ITAT held that the final assessment order passed under section 143(3) read with section 144C(13) was time-barred. The AO was required to complete the assessment within one month from the end of the month in which directions were received from the DRP. Since the DRP issued directions on 21.09.2021, the assessment should have been completed by 31.10.2021. However, the AO passed the final order on 18.11.2021, beyond the prescribed period. Consequently, the tribunal quashed the assessment order as void ab initio for non-compliance with the statutory time limit, allowing the appeal.
The ITAT held that the final assessment order passed under section 143(3) read with section 144C(13) was time-barred. The AO was required to complete the assessment within one month from the end of the month in which directions were received from the DRP. Since the DRP issued directions on 21.09.2021, the assessment should have been completed by 31.10.2021. However, the AO passed the final order on 18.11.2021, beyond the prescribed period. Consequently, the tribunal quashed the assessment order as void ab initio for non-compliance with the statutory time limit, allowing the appeal.
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