Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
The dominant issue was whether the time-limit for a final assessment order under section 143(3) read with sections 144C(13) and 144B must be computed under section 153(1) read with section 153(4), or under section 144C(13). The Tribunal held that statutory limitation is governed by section 153(1) read with section 153(4), applying consistency with its earlier view, and computed the deadline as 31.12.2020. Since the final assessment order was passed on 12.01.2022, it was beyond the prescribed period; the order was held time-barred and quashed. - ITAT
The dominant issue was whether the time-limit for a final assessment order under section 143(3) read with sections 144C(13) and 144B must be computed under section 153(1) read with section 153(4), or under section 144C(13). The Tribunal held that statutory limitation is governed by section 153(1) read with section 153(4), applying consistency with its earlier view, and computed the deadline as 31.12.2020. Since the final assessment order was passed on 12.01.2022, it was beyond the prescribed period; the order was held time-barred and quashed. - ITAT
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TaxTMI 
TaxTMI 
