Transfer Pricing Assessments Quashed as Time-Barred Despite DRP Directions

Western UP Tollway Limited Vs DCIT (ITAT Hyderabad) DRP route no shield against limitation: ITAT Hyderabad quashes TP assessments as time-barred Hyderabad ITAT in a consolidated order has quashed the final assessment orders passed u/s 143(3) r.w.s. 144C(13) & 144B as being barred by limitation. The Tribunal first admitted the additional legal grounds, holding that a pure question of law arising from facts already on record can be raised at any stage, relying on NTPC Ltd. v. CIT (229 ITR 383). It rejected the Revenue’s objection that such grounds are confined only to cases of non-taxable ...