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

Achampet Solar Private Ltd. Vs ITO (ITAT Delhi) The appeal challenged the final assessment order dated 22-02-2022 passed under Section 143(3) read with Section 144C of the Income Tax Act following the directions of the Dispute Resolution Panel (DRP) dated 14-12-2021. The assessee originally raised grounds against the transfer pricing adjustment relating to management fees of Rs. 1,03,95,878, the rejection of its transfer pricing study, application of the Comparable Uncontrolled Price (CUP) method, capitalization of the management fee, and retention of an adjustment relating to loan repayment d...