Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
