Section 153(5) Timeline Binding Even on ITAT Remand: ITAT Delhi

Hitachi Astemo Haryana Private Limited Vs ACIT (ITAT Delhi) Three-Month Limit Under Section 153(5) is Mandatory – Returned Income Deemed Accepted as AO Missed Section 153(5) Timeline Delhi  Tribunal  allowed the appeal of Assessee by holding that the assessment order passed beyond limitation prescribed u/s 153(5) is invalid & liable to be quashed. TPO in order dated 29.07.2021 proposed TP adjustments of ₹5.54 crore (manufacturing segment) & ₹5.92 crore (royalty payments). DRP granted relief on manufacturing but sustained royalty addition. AO passed final order u/s 143(3) r...