Sec. 92C – Transfer Pricing – Where TPO made upward ALP adjustment on account of AMP expenses incurred by assessee, since no adjustments were made on account of such AMP expenses during earlier assessment years 2009-10 to 2015-16 even though assessee had some business model and facts and circumstances of matter were also similar, in view of rate of consistency, impugned adjustment was to be deleted during year as well.
Amway India Enterprises (P.) Ltd. v. Additional National E-Assessment Centre, New Delhi – [2022] 140 taxmann.com 446 (Delhi-Trib.).
CBDT reduces time limit to verify ITR from 120 days to 30 days for returns filed on or after 01-08-2022.
Notification No. 5/2022, dated 29-07-2022.
SC refers to larger bench the issue whether assessee can challenge certificate u/s 197 issued to him at his ‘without prejudice to my legal position’ request.
National Petroleum Construction Co. v. Deputy Commissioner of Income-tax, Circle 2(2)(IT), New Delhi – [2022] 140 taxmann.com 659 (SC).
Sum disallowed u/s 14A cannot be added to net profit while computing profit for MAT purposes.
ACIT v. Geometric Software Solutions Co. Ltd. – [2022] 140 taxmann.com 647 (Mumbai-Trib.).
No penalty for non-deduction of tax at year end if amount payable to payees was not identifiable.
ACIT v. Parsons Brinckerhoff India (P.) Ltd. – [2022] 140 taxmann.com 645 (Delhi-Trib.).
High Court validates issue of section 148 notice as income in Form 26AS in higher than income disclosed in P&L account.
Distributors India C and F v. UOI – [2022] 140 taxmann.com 338 (Allahabad).