Missed DRP timeline kills TP addition; ₹288 Cr share capital upheld

DCIT Vs Adamas Builders Pvt. Ltd. (ITAT Bangalore) The ITAT Bangalore held that transfer pricing adjustment of ₹12.22 crore could not be sustained as the AO failed to pass a final assessment order pursuant to DRP directions within the prescribed time. Consequently, the adjustment was held to be invalid—not on merits, but due to procedural lapse and lack of jurisdiction in subsequent 263 proceedings. The Tribunal noted that the DRP had issued directions on 20.11.2019, but no final order was passed within the statutory time. Instead, the AO attempted to reintroduce the TP adjustment in a lat...