Assessment Quashed as Final Order Passed Beyond Section 153 Time Limit: ITAT Hyderabad

R.A.K. Ceramics India Private Limited Vs DCIT (ITAT Hyderabad) Section 144C can’t override 153: TP final order for AY 2018-19 quashed as time-barred by ITAT Hyderabad The appeal before the Income Tax Appellate Tribunal, Hyderabad Bench, concerned Assessment Year 2018–19 and raised a purely legal issue relating to limitation for passing the final assessment order in a transfer pricing case governed by the Dispute Resolution Panel (DRP) mechanism. The material facts were undisputed. For the relevant assessment year, the last date for passing the final assessment order, if computed under sect...