https://www.taxtmi.com/caselaws?id=791018 A transfer pricing order dated within the limitation period was treated as timely even though the digital signature was affixed the next day, because the relevant limitation framework under section 92CA(3A) and the proposed clarificatory amendment supported validity within the extended time. The limitation objection therefore failed, and the transfer pricing adjustment was remanded for decision on merits. A separate additional ground seeking dividend distribution tax relief under the India-USA DTAA was not admitted because the necessary residence particulars, Form 10F, and other factual material required under section 90 and Rule 21AB were not on record. An additional ground was rejected where it was not a pure question of law arising from facts already established. en-us Fri, 27 Mar 2026 00:00:00 +0530 Tue, 05 May 2026 09:09:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791018 A transfer pricing order dated within the limitation period was treated as timely even though the digital signature was affixed the next day, because the relevant limitation framework under section 92CA(3A) and the proposed clarificatory amendment supported validity within the extended time. The limitation objection therefore failed, and the transfer pricing adjustment was remanded for decision on merits. A separate additional ground seeking dividend distribution tax relief under the India-USA DTAA was not admitted because the necessary residence particulars, Form 10F, and other factual material required under section 90 and Rule 21AB were not on record. An additional ground was rejected where it was not a pure question of law arising from facts already established. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791018