Transfer Pricing Assessment Invalidated for 144C Violation: ITAT Bangalore Decision

Microsoft Research Lab India Private Limited Vs DCIT (ITAT Bangalore) TP Case- Draft Order Never Served- ITAT Strikes Down Entire 143(3) Order for Violating 144C- DAO Prepared on 15 April, FAA Passed on 23 April — 30-Day Window Violated Assessee challenged the validity of the final assessment order dated 23.04.2021 passed u/s 143(3) r.w.s. 144B, contending that no draft assessment order (DAO) was ever served as required for an eligible assessee in a transfer pricing case. Tribunal examined the complete case-history screenshot & documents placed by the Revenue, which showed that although ...