The assessee contended that the assessment completed on 30-09-2022 was barred by limitation since, in a transfer pricing case, section 153(4) extended the limitation only up to 31-03-2022 and neither the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, nor the CBDT Notifications extended the period for completion of assessment under section 153(4). The Tribunal held that the reference to the TPO merely extended the limitation up to 31-03-2022. As no further statutory extension was available, the assessment order passed on 30-09-2022 was beyond the prescribed period and therefore invalid. (AY. 2009-10)
Dy. CIT v. Dalmia Cement (Bharat) Ltd. (2025) 121 ITR 298 (Chennai)(Trib.)
S. 144C: Reference to dispute resolution panel-Limitation-Assessment-Transfer Pricing –CBDT Notifications-Assessment was time-barred-Invalid. [S. 143(3), 144B, 144C(3), 153(4)]
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