Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
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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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