Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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Time lost by the assessing officer during search-related handover of books of account is excluded from the 180-day limitation under the relevant provision, but only to the extent that the handover period is included in the original limitation period; consequently the excluded period (1/4/2023-22/8/2023, 144 days) extends the assessment deadline to 22/8/2024. The assessment order dated 27/9/2024 was therefore beyond the extended limitation and is time barred, and the assessee's appeal is allowed.
Time lost by the assessing officer during search-related handover of books of account is excluded from the 180-day limitation under the relevant provision, but only to the extent that the handover period is included in the original limitation period; consequently the excluded period (1/4/2023-22/8/2023, 144 days) extends the assessment deadline to 22/8/2024. The assessment order dated 27/9/2024 was therefore beyond the extended limitation and is time barred, and the assessee's appeal is allowed.
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