DRP assessment quashed as time-barred – Section 153 overrides Section 144C timelines

Centre For General Education Society Vs CIT Exemption (ITAT Delhi)

The Delhi ITAT quashed the final assessment order passed u/s 143(3) r.w.s. 144C(13) for AY 2020-21 as barred by limitation, holding that the outer time limit prescribed under section 153 continues to govern even DRP cases.

The Tribunal rejected the Revenue’s plea to defer adjudication merely because t

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