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Income Tax

Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred

Case Law Details

Case Name
Shakti Hormann Private Limited Vs DCIT (ITAT Hyderabad)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2020-21
Advertisement Shakti Hormann Private Limited Vs DCIT (ITAT Hyderabad) 144C Is Not a Time-Extender: TP Assessment Quashed as Time-Barred- Draft Order in Time Won’t Save Final Order: DRP Route Can’t Beat Section 153; The Hyderabad ITAT allowed the Assessee’s appeal on the legal issue and quashed the final assessment order as time-barred, holding that limitation prescribed u/s 153 prevails over the procedure u/s 144C. In the present case, despite reference to the TPO u/s 92CA and issuance of draft assessment order u/s 144C(1) on 26-09-2023, the final assessment order u/s 143(3) r.w.s. 14...
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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 5,928

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