Allowing the appeal of the revenue the Court held that ; period from date when Assessing Officer directs special audit till last date of furnishing such report under section 142 (2A) shall be excluded and not counted for limitation. Accordingly the draft assessment order is not bared by limitation. (AY. 2008-09)
PCIT v. AT & T Global Network Services (India) (P.) Ltd. (2018) 258 Taxman 197 / 305 CTR 283/ 169 DTR 473(Delhi)(HC)
S. 153 : Assessment- Limitation -Special audit- Period from date when Assessing Officer directs special audit till last date of furnishing such report under section 142 (2A) shall be excluded and not counted for limitation- Accordingly the draft assessment order is not bared by limitation.[ S.142(2A)]