TPO passed order u/s. 92CA(3) wherein he proposed adjustment. AO enhanced income declared by assessee by making adjustment on account of arm’s length price in respect of international transactions entered into by assessee with its associate enterprise. CIT (A) confirmed the addition. Dismissing the appeal of the assessee the Tribunal held that if the assessee had any objections on proposed additions by AO, it should have filed such objections within 30 days before DRP and AO. However, since assessee had not filed any objections before DRP an AO, then ground of Assessee is not sustainable. (AY. 2011-12)
Jaipur Rugs Co. P. Ltd. v. DCIT (2018) 64 ITR 128 / 193 TTJ 49 (UO)(Jaipur)(Trib.)
S. 143(3) : Assessment-Validity-Draft order wrongly titled as assessment order–Objection was not raised before DRP-Validity of assessment cannot be challenged. [S. 92CA, 144C]