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 TPO's order under s.92CA(3) is time-barred by one day and therefore invalid. The tribunal found the assessment limitation under s.153(1) expired on 31 Mar 2013, so the statutory 60-day cutoff for issuing an order under s.92CA(3A) lapsed on 29 Jan 2013; reliance on a departmental circular using the phrase "two months" could not supplant the statutory "60 days" calculation. Applying the statutory timeline strictly, the TPO's s.92CA order was barred by limitation and set aside, and the assessee's appeal was allowed.
The ITAT held that the TPO's order under s.92CA(3) is time-barred by one day and therefore invalid. The tribunal found the assessment limitation under s.153(1) expired on 31 Mar 2013, so the statutory 60-day cutoff for issuing an order under s.92CA(3A) lapsed on 29 Jan 2013; reliance on a departmental circular using the phrase "two months" could not supplant the statutory "60 days" calculation. Applying the statutory timeline strictly, the TPO's s.92CA order was barred by limitation and set aside, and the assessee's appeal was allowed.
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