Taeyang Metal India (P.) Ltd. v. Dy. CIT (2024)470 ITR 705 /160 taxmann.com 536 (Mad) (HC)

S. 144C : Reference to dispute resolution panel-Time limit-Direction of DRP-Uploading on ITBA portal on 17-6-2022-Final assessment order was passed on 25-3-2023-Order is barred by limitation. [S.92CA, 144B, 144C(13), Art. 226]

The petitioner challenged the assessment order by filing the writ petition on the ground  that the order is barred by limitation.  Allowing the petition the Court  held that the  period of limitation for passing an assessment order upon receipt of directions from DRP is one month from end of month in which directions are received. Directions of DRP were forwarded to Assessing Officer by uploading same on 17-6-2022, period of limitation for computing time for passing assessment order would start from 30-6-2022 and, thus, final assessment order passed on 25-3-2023, beyond time limit specified in section 144C(13), is  barred by limitation. (AY. 2018-19)

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