Home Highlights April 2019 Year 2019 This

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1. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

2. Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he...

3. Capital Gain - Transfer u/s 2(47)(v) - assessment year - AO himself has given credit for the amount of capital gains declared for the assessment year 2013-14, while...

4. Transfer pricing - the transaction in the instant case of sale of shares in ‘AB’ International will have to be benchmarked as per the transfer pricing provisions...

5. Validity of the draft assessment order issued in the name of non-existent entity - TP adjustment - arm’s-length price u/s 92CA - once the draft assessment order and...

6. Validity of order u/s 92CA - time limit for passing of the TPO order - period of limitation - despite the fact that the reference made to the Ld. TPO is valid, in...

7. Transfer Pricing Adjustments - Validity of the order passed u/s. 92CA(3) - period of limitation - 60 days have to be counted prior to the date of last date of limitation...

8. Validity of assessment order - Amalgamation - transfer pricing order u/s. 92CA(3) was passed against non-est (amalgamated) company - assessment order though passed in...

9. Transfer pricing - Validity of the final assessment order passed u/s 144C(13) - Period of limitation - In the instant case, the manual final assessment order is dated 24....

10. Reopening of assessment u/s 147 - Computation of book profits u/s 115JB - MAT - if AO during scrutiny assessment notices a claim of exemptions made by the assessee...

11. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

12. Assessment u/s 153C - Addition u/s 69A - Certain incriminating documents/information contained in the seized material pertained to the assessee, the proprietor found...

13. TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment...

14. Validity of unsigned order - Final assessment order not signed by the AO - DR submitted that the additions made in the draft assessment order and the final assessment...

15. Validity of assessment u/s 144C - Non passing draft Assessment Order - TP Adjustment - AO merely captioned the final Assessment Order as Draft Assessment Order along...