Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
HC held that the Assessing Officer was bound by section 144C(13) to complete the assessment within one month from the end of the month in which the DRP's directions under s.144C(5) were received, and had no discretionary power to extend or deviate from that mandate. The court rejected Revenue's contention that remand cases are exempt from the statutory timeline, treating the provision as mandatory and equally applicable on remand. Because the AO failed to give effect to the DRP directions within the prescribed period, any transfer-pricing addition sought thereafter cannot be sustained beyond the statutory timeline and the AO's action in completing the assessment late is impermissible.
HC held that the Assessing Officer was bound by section 144C(13) to complete the assessment within one month from the end of the month in which the DRP's directions under s.144C(5) were received, and had no discretionary power to extend or deviate from that mandate. The court rejected Revenue's contention that remand cases are exempt from the statutory timeline, treating the provision as mandatory and equally applicable on remand. Because the AO failed to give effect to the DRP directions within the prescribed period, any transfer-pricing addition sought thereafter cannot be sustained beyond the statutory timeline and the AO's action in completing the assessment late is impermissible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
