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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Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
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