ITAT Hyderabad quashes final TP assessment as time-barred despite DRP directions

TMEIC Industrial Systems India Private Limited Vs DCIT (ITAT Hyderabad) Hyderabad   ITAT quashed the final assessment order passed u/s 143(3) r.w.s. 144C(13) & 144B as being barred by limitation. The Tribunal first admitted the additional legal grounds raised by the Assessee, holding that questions of law arising from facts already on record can be raised at any stage, relying on NTPC Ltd. v. CIT (229 ITR 383). On merits, it held that the outer time-limit prescribed u/s 153(1) r.w.s. 153(4) prevails even in cases governed by the DRP mechanism u/s 144C. For AY 2020-21, the normal limitati...