Validity assessment order - DRP issued directions (order) ...

Assessment Order Quashed: DRP Directions Invalid Without Document Identification Number; Section 292B Argument Rejected.

September 22, 2023

Case Laws Income Tax AT

Validity assessment order - DRP issued directions (order) without quoting DIN - the argument advanced on behalf the revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the circular 19/2019. - final assessment order quashed - AT

View Source

← Previous Next →

Validity assessment order - DRP issued directions (order) ...

Assessment Order Quashed: DRP Directions Invalid Without Document Identification Number; Section 292B Argument Rejected.

September 22, 2023

Case Laws Income Tax AT

You may also like:

DRP directions without a valid computer-generated Document Identification Number (DIN) allotted and quoted in the body of the order are invalid and deemed never issued....

TP adjustment - AO/TPO has not followed direction of DRP - As per section 144C(13) the AO is bound to pass the final assessment order in conformity with the direction of...

Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid...

Assessment u/s 144C(13) in pursuant to the directions of DRP - In the case in hand, the direction for verification as issued were colourable and the Latin maxim “Quando...

Assessment u/s 144C - Royalty receipt - income from distribution of software licenses and providing support services - AO has not followed the directions of the DRP and...

Validity of the final assessment order due to non-service of the Dispute Resolution Panel’s (DRP) directions - AR candidly admitted before the Tribunal that, on the...

The High Court ruled on the validity of an order passed u/s 144C(3) read with Section 144B. The petitioner had filed objections to the Draft Assessment Order before the...

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

HC ruled that time limits under Section 144C(13) for completing assessments following DRP directions are mandatory, not directory. The AO must pass orders within one...

Validity of the final assessment order due to non-implementation of the directions of learned DRP - Royalty/FTS receipts - The ITAT underscored the legal requirement u/s...

Digital images and Excel files found on partner's phone cannot be relied upon for making additions u/s 69C for unexplained expenditure. Loose papers and documents not...

Rectification of mistake u/s 154 - TP Adjustment - arm's length price adjustment - even after holding that there was no apparent mistake in the DRP directions, whereas a...

TP Adjustment - applicability of Section 144C(13) - As provided in the Section 144C(13) of the Act, the final order of the Assessing Officer should be in conformity with...

TP Adjustment - Rate of interest for the purpose of calculating working capital adjustment - AO/TPO, while giving effect to the directions of the DRP, were bereft of any...

Scrutiny Assessment u/s 143(3) after direction of DRP u/s. 144C - time barred assessment - The final assessment order has been passed after the end of one month from the...

Quick Updates: