Time-Barred TPO Order Renders Assessee Ineligible

Asus India Private Limited Vs ITO (ITAT Mumbai) ITAT Mumbai held that the moment the order of the TPO is barred by limitation and quashed, the assessee ceases to be an ‘eligible assessee’. Hence, the time limit for completion of the assessment reverts back to 21 months. Final assessment order passed after that is barred by limitation. Facts- As the assessee engaged in the business of distribution of Asus Group products in India whereby it purchases Notebooks and Tablets from its associated enterprises and sales the product locally, it entered into several international transaction. Therefo...