Final Assessment Set Aside Due to Limitation Breach After Invalid TP Order

Saint Gobain India Pvt. Ltd. DCIT (ITAT Chennai) TP Order Time-Barred ⇒ Assessee Ceases to Be “Eligible Assessee”; Final Assessment Beyond Limitation Quashed The Chennai Bench of the ITAT, in M/s Saint Gobain India Pvt. Ltd. vs. DCIT (ITA Nos. 1505 & 1672/Chny/2024, AY 2016-17, order dated 18-Dec-2025), quashed the final assessment order dated 28-02-2020 passed u/s 143(3) r/w s.144C, holding that the assessment was barred by limitation and hence void ab initio. The Tribunal noted that the Transfer Pricing Officer’s order dated 01-11-2019 had already been held to be time-barred by t...