DRP issued directions under section 144C(5) on 22-04-2022, and TPO passed an order giving effect to the DRP direction on 20-05-2022 and subsequently, an assessment order came to be passed on 28-06-2022. Since the assessment order was passed beyond the period of limitation prescribed under section 144C(13), the same was set aside.(AY. 2011-12)
BMW India (P.) Ltd. v. ACIT (2025) 215 ITD 21 (Delhi) (Trib.)
S. 144C: Reference to dispute resolution panel-Limitation-Final assessment order dated 28-06-2022 was passed after DRP directions on 22-4-2022-Beyond the time limit prescribed under section 144C(13) Barred by limitation-Order was quashed.[S.92CA, 144C(13)]
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