Extension of timelines for filing of various reports of audit for the Assessment Year 2024-25 - Taxindiainternational.com

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I-T – Assessment order is void if limited scrutiny case is converted to complete scrutiny without prior written approval from PCIT: ITAT (See Breaking News)

I-T – Payments for automated online advertisement services on foreign platforms do not constitute royalty: ITAT (See Breaking News)

TP - Pass-through costs incurred for third-party services without any value addition by tested party must be excluded from operating cost base for margin calculations: ITAT (See Breaking News)

Make believe 'make available' (See TII Edit)

TP - TPO not justified in determining ALP as nil without applying any recognised method prescribed u/s 92C; cannot questioning commercial expediency of expenditure once actual rendition of services is established: ITAT (See Breaking News)

TP - Companies functionally different from captive, limited-risk service provider, or companies lacking reliable segmental data, cannot be retained as comparables: ITAT (See Breaking News)

I-T - If tax department has historically granted lower withholding tax certificates based on uncontested history of financial losses, competent authority cannot suddenly impose higher rate: HC (See Breaking News)

I-T - For eligible assessee covered by Sec 144C, final assessment order must still be passed within outer limitation prescribed u/s 153 r/w/s 144C: ITAT (See Breaking News)

INTL - A literal interpretation of Section 9(1)(i) applies only when capital asset explicitly situated in India is transferred; this legal fiction cannot be stretched to cover indirect transfers of foreign shares: ITAT (See Breaking News)

I-T - Remittance of part of earmarked foreign grant by a Sec 12A-registered charitable society to University of Texas for collaborative research project cannot be disallowed as application of income outside India: ITAT (See Breaking News)

TP - If BAPA fixes arm's length operating margin for IT and ITES transactions with covered US-based AEs, and transaction with uncovered non-US AE is undisputedly identical on FAR analysis, same BAPA margin can be adopted for uncovered AE as well: ITAT (See Breaking News)

I-T - For determining limitation in DRP cases, Sec 144C & Sec 153 must be read together: ITAT (See Breaking News)

Rethinking Royalty in the Digital Age - What AWS and Salesforce Judgments Mean (See TII SPECIAL)

TP - Unsupported website extracts or third-party database information can override disclosures made in audited financial statements: ITAT (See Breaking News)

TP - Notional interest cannot be separately added on delayed AE receivables if TNMM benchmarking with working capital adjustment is already accepted: ITAT (See Breaking News)

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Extension of timelines for filing of various reports of audit for the Assessment Year 2024-25 By TII News Service Sep 29, 2024 , New Delhi
Untitled Document GOVERNMENT OF INDIA MINISTRY OF FINANCE DEPARTMENT OF REVENUE CENTRAL BOARD OF DIRECT TAXES NEW DELHI CIRCULAR NO 10/2024; Dated: September 29, 2024 Subject: - Extension of timelines for filing of various reports of audit for the Assessment Year 2024-25- reg. On consideration of difficulties faced by the taxpayers and other stakeholders in electronic filing of various reports of audit under the provisions of the Income-tax Act, 1961 (Act), the Central Board of Direct Taxes (CBDT), in exercise of its powers under Section 119 of the Act, extends the specified date of furnishing of report of audit under any provision of the Act for the Previous Year 2023-24, which was 30th September, 2024 in the case of assessees referred in clause (a) of Explanation 2 to sub-section (1) of section 139 of the Act, to 07th October, 2024. [F. No. 225/205/2024/ITA-II] (Dr. Castro Jayaprakash.T) Under Secretary to the Government of India

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