Final assessment order u/s. 143(3) quashed as passed beyond time prescribed u/s. 153(4)

NetCracker Technology Solutions (India) Private Limited Vs DCIT (ITAT Hyderabad)

ITAT Hyderabad held that the final assessment order passed by the A.O. u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024 beyond the limitation prescribed under Section 153(4) of the Income-tax Act, 1961 is liable to be quashed. Accordingly, the appeal is allowed.

Facts- During TP proceeding, TP made adjustment of Rs. 4,56,91,941/- in respect of interest on trade receivables from AE by applying SBI short-term deposit rate and also after allowing a credit period of 60 days

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