ITAT Hyderabad Quashes Assessment as DRP Route Cannot Extend Section 153 Limitation

Aveva Solutions India LLP Vs ITO (ITAT Hyderabad)

DRP Route Cannot Extend Limitation: Assessment Beyond Section 153 Limit Struck Down by ITAT Hyderabad

Tribunal examined the core legal issue of limitation for passing assessment u/s 143(3) r.w.s. 144C(13) in a Transfer Pricing case. Assessee contended that once the assessment year is 2021-22, the statutory time limit u/s 153(1) (read with third proviso reducing the limit to 9 months) expired on 31.12.2022, & with reference to TPO u/s 92CA, the extended limitation u/s 153(4) permitted completion only up to

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