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...
Interplay between section 144C and section 153 requires determination of limitation for passing final assessment orders by reference to both provisions construed together; this mutual and harmonious construction was applied to hold that final assessment orders rendered beyond the combined time limits are barred by limitation and therefore quashed. An interim stay of a precedent does not negate its ratio decidendi, but reliance in the instant case was placed on an unstayed High Court decision; accordingly the appeal was heard and the Departments preliminary objection rejected, resulting in annulment of time-barred assessment orders.
Interplay between section 144C and section 153 requires determination of limitation for passing final assessment orders by reference to both provisions construed together; this mutual and harmonious construction was applied to hold that final assessment orders rendered beyond the combined time limits are barred by limitation and therefore quashed. An interim stay of a precedent does not negate its ratio decidendi, but reliance in the instant case was placed on an unstayed High Court decision; accordingly the appeal was heard and the Departments preliminary objection rejected, resulting in annulment of time-barred assessment orders.
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