Charity-run tree plantation and maintenance for environmental preservation qualifies as "charitable activity", making supplies GST-exempt under Notifi...
Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
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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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