Assessment Quashed as Final Order Passed Beyond Section 153 Time Limit: ITAT Hyderabad

R.A.K. Ceramics India Private Limited Vs DCIT (ITAT Hyderabad)

Section 144C can’t override 153: TP final order for AY 2018-19 quashed as time-barred by ITAT Hyderabad

The appeal before the Income Tax Appellate Tribunal, Hyderabad Bench, concerned Assessment Year 2018–19 and raised a purely legal issue relating to limitation for passing the final assessment order in a transfer pricing case governed by the Dispute Resolution Panel (DRP) mechanism. The material facts were undisputed.

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