The final assessment order was passed more than six months after receipt of the Dispute Resolution Panel’s directions. The Tribunal held that under section 144C(13), the Assessing Officer is required to pass the final assessment order within one month from the end of the month in which the directions are received. The Transfer Pricing Officer’s effect order could not extend the statutory limitation. Accordingly, the final assessment order passed beyond the prescribed period was barred by limitation and void ab initio. (AY. 2018-19).
Adidas India Marketing (P.) Ltd. v. Asst. CIT (2025) 123 ITR 267 (Delhi)(Trib.)
S. 144C : Reference to dispute resolution panel-Assessment-Directions of Dispute Resolution Panel-Final assessment order passed beyond statutory time-limit-Order barred by limitation and void.[S. 144B, 144C(5), 144C(13)]
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