Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
The dominant issue was the statutory limitation for passing the final assessment order under section 144C(13), i.e., whether the time limit is governed by section 153(1) read with section 153(4) or by section 144C(13) (one month from the end of the month of DRP directions). Relying on a coordinate bench ruling on an identical question, the Tribunal held that limitation must be computed under section 153(1) read with section 153(4), making the last permissible date 30.09.2023. Since the final assessment order was passed on 29.07.2024, it was held time-barred and was quashed. - ITAT
The dominant issue was the statutory limitation for passing the final assessment order under section 144C(13), i.e., whether the time limit is governed by section 153(1) read with section 153(4) or by section 144C(13) (one month from the end of the month of DRP directions). Relying on a coordinate bench ruling on an identical question, the Tribunal held that limitation must be computed under section 153(1) read with section 153(4), making the last permissible date 30.09.2023. Since the final assessment order was passed on 29.07.2024, it was held time-barred and was quashed. - ITAT
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