ITAT Quashes Assessment as Final Order Was Passed Beyond Section 144C Limitation

Adidas India Marketing Private Limited Vs ACIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, considered the assessee’s appeal against the final assessment order dated 28.02.2023 passed under Sections 143(3) and 144C(13) for Assessment Year 2018-19. The assessee raised several grounds relating to transfer pricing adjustments, royalty, buying commission, corporate tax issues, jurisdiction, and limitation. Since the challenge to the validity of the assessment on jurisdiction and limitation was a legal issue, the Tribunal decided those grounds first. Assessee’s Contenti...