Extended time limit not available as assessee ceases to be an ‘eligible assessee’

Johnson & Johnson Private Ltd Vs DCIT (ITAT Mumbai) ITAT Mumbai held that as the assessee ceases to be an ‘eligible assessee’ under provisions of section 144C of the Income Tax Act, extended time limit for assessment is not available to AO. Accordingly, order of TPO is barred by limitation. Facts- Assessee Company is subsidiary of M/s Johnson & Johnson, USA, engaged in the business of manufacturing and marketing of various consumer care, healthcare and diagnostic products. It has five different divisions in India. The learned Transfer Pricing Officer passed order under Section 92CA...