Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
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The HC held that DRP directions uploaded to the ITBA portal with a DIN on 26.05.2022 constitute receipt by the assessing officer for limitation purposes under section 144C(13). Uploading ipso facto effects service; physical speed-post receipt on 01.06.2022 was inconsequential. Consequently the one-month limitation period expired on 30.06.2022 and the assessment order passed on 01.07.2022 is time-barred and therefore invalid. The court rejected the Revenue's contention that international taxation matters fall outside electronic communication, noting DRP directions were uploaded by the Revenue and electronic service under the e-Assessment Scheme governs computation of limitation. No substantial question of law arises.
The HC held that DRP directions uploaded to the ITBA portal with a DIN on 26.05.2022 constitute receipt by the assessing officer for limitation purposes under section 144C(13). Uploading ipso facto effects service; physical speed-post receipt on 01.06.2022 was inconsequential. Consequently the one-month limitation period expired on 30.06.2022 and the assessment order passed on 01.07.2022 is time-barred and therefore invalid. The court rejected the Revenue's contention that international taxation matters fall outside electronic communication, noting DRP directions were uploaded by the Revenue and electronic service under the e-Assessment Scheme governs computation of limitation. No substantial question of law arises.
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