Section 144C doesn’t extend outer time limit: ITAT Hyderabad quashes TP final order as barred by limitation

Parexel International (IRL) Limited Vs ADIT (ITAT Hyderabad) Hyderabad ITAT,   allowed Assessee’s appeal &  quashed the final assessment order passed u/s 143(3) r.w.s. 144C(13) as being barred by limitation u/s 153. Tribunal admitted an additional legal ground holding that limitation goes to the root of jurisdiction &  can be adjudicated on admitted facts, relying on NTPC Ltd. ITAT held that even in the case of an “eligible assessee” covered by DRP procedure, section 144C does not override or extend the outer statutory time limit prescribed u/s 153(1) read with section 153(4)...