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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT allowed the assessee's appeal and set aside the impugned assessment order as barred by limitation. The Tribunal held that after DRP issued directions u/s 144C(5) on 22/04/2022 and the TPO gave effect on 20/05/2022, the assessing officer was mandated by s.144C(13) to complete assessment within one month from the end of that month; the assessment dated 28/06/2022 exceeded the statutory timeline. Reliance was placed on precedent establishing the mandatory nature of the timeline under s.144C(13), such that failure to complete assessment within the prescribed period renders the proceedings time-barred. The rectification order did not cure the limitation defect.
ITAT allowed the assessee's appeal and set aside the impugned assessment order as barred by limitation. The Tribunal held that after DRP issued directions u/s 144C(5) on 22/04/2022 and the TPO gave effect on 20/05/2022, the assessing officer was mandated by s.144C(13) to complete assessment within one month from the end of that month; the assessment dated 28/06/2022 exceeded the statutory timeline. Reliance was placed on precedent establishing the mandatory nature of the timeline under s.144C(13), such that failure to complete assessment within the prescribed period renders the proceedings time-barred. The rectification order did not cure the limitation defect.
Note: It is a system-generated summary and is for quick reference only.