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Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred
Case Law Details
- Case Name
- Shakti Hormann Private Limited Vs DCIT (ITAT Hyderabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Hyderabad
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Shakti Hormann Private Limited Vs DCIT (ITAT Hyderabad)
144C Is Not a Time-Extender: TP Assessment Quashed as Time-Barred- Draft Order in Time Won’t Save Final Order: DRP Route Can’t Beat Section 153;
The Hyderabad ITAT allowed the Assessee’s appeal on the legal issue and quashed the final assessment order as time-barred, holding that limitation prescribed u/s 153 prevails over the procedure u/s 144C.
In the present case, despite reference to the TPO u/s 92CA and issuance of draft assessment order u/s 144C(1) on 26-09-2023, the final assessment order u/s 143(3) r.w.s. 14...




