Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Validity of a reference to the Transfer Pricing Officer was assessed on limitation grounds: the proviso extending assessment time for notices issued on or after 01.04.2019 gave a twelvemonth period, so a notice served 24.02.2020 required completion by 31.03.2021; tolling under pandemic ordinances extended that to 30.06.2021. Approval for reference was recorded on 10.02.2021, but the actual reference reached the TPO only in January 2022. The court concluded the TPO's determination and consequent draft assessment were made without jurisdiction because the reference was not made within the statutory limitation period, rendering the TPO order invalid.
Validity of a reference to the Transfer Pricing Officer was assessed on limitation grounds: the proviso extending assessment time for notices issued on or after 01.04.2019 gave a twelvemonth period, so a notice served 24.02.2020 required completion by 31.03.2021; tolling under pandemic ordinances extended that to 30.06.2021. Approval for reference was recorded on 10.02.2021, but the actual reference reached the TPO only in January 2022. The court concluded the TPO's determination and consequent draft assessment were made without jurisdiction because the reference was not made within the statutory limitation period, rendering the TPO order invalid.
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