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...
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Section 73(9) does not permit the Proper Officer to determine tax liability before the statutory due date for filing the annual return for the relevant financial year has expired. An assessment made before that deadline is premature and beyond the Proper Officer's authority. The premature assessment order was set aside, with fresh assessment proceedings to be undertaken in accordance with law after proper notice and an opportunity of hearing.
Section 73(9) does not permit the Proper Officer to determine tax liability before the statutory due date for filing the annual return for the relevant financial year has expired. An assessment made before that deadline is premature and beyond the Proper Officer's authority. The premature assessment order was set aside, with fresh assessment proceedings to be undertaken in accordance with law after proper notice and an opportunity of hearing.
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