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    <title>2026 (6) TMI 1168 - ITAT HYDERABAD</title>
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    <description>Where the Tribunal had remanded the advances to associated enterprises issue for factual verification, the resulting action was treated as falling under section 153(3) of the Income-tax Act, 1961; where it had already given a conclusive finding on corporate guarantee commission, the Assessing Officer was only required to give effect under section 153(5). In both situations, the impugned assessment orders were passed beyond the applicable limitation period and were therefore held time-barred. The same limitation reasoning was applied to the assessment year involving corporate guarantee and outstanding receivables, and the consequential orders were struck down, leaving the substantive transfer pricing grounds undecided.</description>
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    <pubDate>Thu, 30 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 1168 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=793787</link>
      <description>Where the Tribunal had remanded the advances to associated enterprises issue for factual verification, the resulting action was treated as falling under section 153(3) of the Income-tax Act, 1961; where it had already given a conclusive finding on corporate guarantee commission, the Assessing Officer was only required to give effect under section 153(5). In both situations, the impugned assessment orders were passed beyond the applicable limitation period and were therefore held time-barred. The same limitation reasoning was applied to the assessment year involving corporate guarantee and outstanding receivables, and the consequential orders were struck down, leaving the substantive transfer pricing grounds undecided.</description>
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