Section 153C Limitation Counts From Handover, Not Search: ITAT Quashes Assessment

SRF Limited Vs ACIT (ITAT Delhi) TP adjustments on MSS & reimbursements deleted; functional comparability can’t be diluted even under TNMM — ITAT Delhi in SRF Ltd Delhi Tribunal partly allowed Assessee’s appeals and granted substantial relief on transfer pricing issues, following Assessee’s own precedents. On Management Support Services (MSS), Tribunal held that functional comparability is paramount even under TNMM, and standards of comparability cannot be diluted merely because a broad-based method is adopted. Respectfully following DRP directions in Assessee’s own case for AY 2...