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Transfer Pricing Assessment Invalidated for 144C Violation: ITAT Bangalore Decision
Case Law Details
- Case Name
- Microsoft Research Lab India Private Limited Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Bangalore
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Microsoft Research Lab India Private Limited Vs DCIT (ITAT Bangalore)
TP Case- Draft Order Never Served- ITAT Strikes Down Entire 143(3) Order for Violating 144C- DAO Prepared on 15 April, FAA Passed on 23 April — 30-Day Window Violated
Assessee challenged the validity of the final assessment order dated 23.04.2021 passed u/s 143(3) r.w.s. 144B, contending that no draft assessment order (DAO) was ever served as required for an eligible assessee in a transfer pricing case. Tribunal examined the complete case-history screenshot & documents placed by the Revenue, which showed that although ...
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