Lubrizol Advanced Materials India (P.) Ltd. v. A. unit (ITD) (2024) 205 ITD 312 (Mum) (Trib.)

S. 144C : Reference to dispute resolution panel-Limitation period-
Order is passed beyond one month from end of month in which directions of DRP were received by Assessing Officer-Barred by limitation. [S.92C, 144C(13) R.11]

Assessee provided market support services to its associated enterprises. As its transactions involved international transactions, issue was referred to TPO who made TP adjustment.  Assessee filed objections before DRP and directions of DRP were passed on 14-6-2022.The  assessment order was passed on 1-8-2022. Tribunal held that  assessment order dated 1-8-2022 passed after one month from end of month in which directions of DRP were received by Assessing Officer, on 14-6-2022, was time barred. (AY. 2018-19)

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