https://www.taxtmi.com/highlights?id=99469 The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law. en-us Tue, 05 May 2026 09:09:34 +0530 Tue, 05 May 2026 09:09:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99469 The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law. Highlights Income Tax Tue, 05 May 2026 09:09:34 +0530 https://www.taxtmi.com/highlights?id=99469