ITAT Quashes Assessment as Final Order Was Passed Beyond Section 144C(13) Time Limit

M/s. Cognizant Technology Solutions India Private Limited (as successor-ininterest of M/s. KBACE Technologies Private Limited) Vs ACIT (ITAT Chennai) The assessee appealed against the assessment order dated 18.05.2023 passed under Sections 143(3) read with Sections 144C, 92CA and 254 of the Income-tax Act, challenging a transfer pricing adjustment of ₹83,07,240. The assessee primarily contended that the assessment order was barred by limitation and therefore liable to be quashed. The assessee explained that KBACE Technologies Private Ltd., a wholly owned subsidiary of KBACE US engaged in Ora...