WebThe TPO rejected M/s Imericus Technologies India Pvt. Ltd. as comparable holding that the said company was incorporated in 2002 only and its networth was negative whereas turnover was also less than the turnover of the tested party. Accordingly, the TPO passed an order under Section 92CA(3) ITA No. 594 of 2010 -3-appeal before the Commissioner of WebSep 6, 2024 · 92CA deals with provision for reference to TPO for computation of arms length price in relation to an international transactions. Sub-section (2A) inserted w.e.f. 1.6.2011 further empowers the TPO to take cognizance of transactions not referred to him but come to his notice during the course of proceedings before him.
In view of the above arguments it has been submitted - Course Hero
WebJul 2, 2024 · Section 92CA of the Income-tax Act, 1961 (‘ITA’) WebHere in this case, the order of TPO has been passed on 31st January 2016 and accordingly, the TPO order is clearly barred by limitation by one day by virtue of time limit provided under section 92CA(3). The TPO order admittedly has been passed after the limitation has expired and consequently, the same has to be treated as bad in law and is ... cyber resilience act 2022
Reference to Transfer Pricing officer & Assessment
WebMar 11, 2016 · 4.1 The role of the TPO begins after a reference is received from the AO. In terms of Section 92CA, this role is limited to the determination of the ALP in relation to international transactions or specified domestic transactions referred to him by the AO. WebSection 92CA - Reference to Transfer Pricing Officer (TPO) - International Taxation - Income Tax. ..... Officer may, for the purposes of determining the arm’s length price … WebMay 4, 2024 · Section 92CA (3A) of the IT Act provides for timeframe for passing of TP Order. The provision says that where a reference to the TPO is made, TP Order ‘may' be passed at any time before 60 days prior to the date on which the period of limitation for passing assessment order expires. cyber resilience bot