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...
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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