United Spirits Case: Remand in TP Case Does Not Extend Section 153 Limitation

United Spirits Limited Vs DCIT (Karnataka High Court) United Spirits Limited, had filed returns for Assessment Years 2013–14 and 2014–15 and was subjected to transfer pricing (TP) adjustments under Section 92CA of the Income-tax Act due to its international transactions. Draft assessment orders and final assessment orders were passed after directions from the Dispute Resolution Panel, resulting in substantial additions to income. The assessee challenged these orders before the Income Tax Appellate Tribunal (ITAT), which partly allowed the appeals and remitted certain issues to the authorit...