https://www.taxtmi.com/caselaws?id=241947 Transfer pricing disputes may require fresh examination where additional grounds challenge the most appropriate method and earlier-year findings need verification. Such grounds can be considered where they go to the root of the controversy, subject to an opportunity of hearing before reassessment. For salary expenditure subject to tax deduction at source, delayed deposit affects the year in which the deduction is allowable: payment by the section 139(1) due date permits deduction in the relevant year, while later payment shifts allowability to the year of payment. These issues require recomputation and fresh determination on the applicable facts. en-us Tue, 21 May 2013 00:00:00 +0530 Sat, 04 Jan 2014 07:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=241947 Transfer pricing disputes may require fresh examination where additional grounds challenge the most appropriate method and earlier-year findings need verification. Such grounds can be considered where they go to the root of the controversy, subject to an opportunity of hearing before reassessment. For salary expenditure subject to tax deduction at source, delayed deposit affects the year in which the deduction is allowable: payment by the section 139(1) due date permits deduction in the relevant year, while later payment shifts allowability to the year of payment. These issues require recomputation and fresh determination on the applicable facts. Case-Laws Income Tax Tue, 21 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=241947