Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The dominant issue was whether the Assessing Officer could pass an order giving effect to DRP directions after expiry of the one-month period mandated by section 144C(13). The court held that section 144C(13) imposes a strict, mandatory timeline, and statutory requirements must be complied with in the prescribed manner; treating the time limit as directory would negate the provision's mandatory character. Since the one-month period had already lapsed, the pending proceedings to give effect to the DRP directions, including the transfer pricing addition, were barred by limitation and could not be continued under section 144C(13). - HC
The dominant issue was whether the Assessing Officer could pass an order giving effect to DRP directions after expiry of the one-month period mandated by section 144C(13). The court held that section 144C(13) imposes a strict, mandatory timeline, and statutory requirements must be complied with in the prescribed manner; treating the time limit as directory would negate the provision's mandatory character. Since the one-month period had already lapsed, the pending proceedings to give effect to the DRP directions, including the transfer pricing addition, were barred by limitation and could not be continued under section 144C(13). - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
