Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
The ITAT held that the transfer pricing order u/s 92CA(3) was passed beyond the statutory period of 60 days prior to the limitation date for completing the assessment. Calculating the 60-day backward period, the Tribunal concluded that the last permissible date for passing the TP order was 29.01.2015, whereas the order was actually passed on 30.01.2015. Following binding HC precedent on identical limitation computation, the ITAT declared the TP order time barred, quashed it, and consequently deleted the entire TP adjustment, allowing the assessee's appeal.
The ITAT held that the transfer pricing order u/s 92CA(3) was passed beyond the statutory period of 60 days prior to the limitation date for completing the assessment. Calculating the 60-day backward period, the Tribunal concluded that the last permissible date for passing the TP order was 29.01.2015, whereas the order was actually passed on 30.01.2015. Following binding HC precedent on identical limitation computation, the ITAT declared the TP order time barred, quashed it, and consequently deleted the entire TP adjustment, allowing the assessee's appeal.
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