DRP Route Cannot Extend Statutory Time Limit Under Section 153

DSM Shared Services India Private Limited Vs DCIT (ITAT Hyderabad) ITAT Hyderabad quashes TP assessment as time-barred; DRP route cannot override section 153 Hyderabad ITAT quashed the final assessment order passed u/s 143(3) r.w.s. 144C(13) & 144B as being barred by limitation. The Assessee challenged the final assessment order dated 23-10-2024 on the legal ground that it exceeded the outer time-limit prescribed u/s 153(1) r.w.s. 153(4). The Tribunal noted that for AY 2021-22, the normal limitation of 9 months from the end of the AY was applicable, which stood extended by 12 months due to...