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...
The note addresses limitation for passing final assessment orders where the start of limitation is triggered by a prior Tribunal order; it applies the principle that the limitation period begins from the date of the Tribunal order, obliging the assessing officer to complete the final assessment within the statutory window following that fiscal year-end. Because the DRP issued directions after that prescribed period, the final assessment became time-barred and could not be validly completed. The practical effect: assessments for the relevant year were quashed as barred by limitation and the assessee's challenge succeeds on that ground.
The note addresses limitation for passing final assessment orders where the start of limitation is triggered by a prior Tribunal order; it applies the principle that the limitation period begins from the date of the Tribunal order, obliging the assessing officer to complete the final assessment within the statutory window following that fiscal year-end. Because the DRP issued directions after that prescribed period, the final assessment became time-barred and could not be validly completed. The practical effect: assessments for the relevant year were quashed as barred by limitation and the assessee's challenge succeeds on that ground.
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