Teejay India P. Ltd. v. Dy. CIT (2023)103 ITR 52 (Vishakha) (Trib)

S. 144C : Reference to dispute resolution panel-Assessing Officer passing final assessment order before Transfer Pricing Officer gave effect to directions of Dispute Resolution Panel-Final assessment order rectified on application of assessee after Transfer Pricing Officer gave effect to directions-Rectified final assessment order deemed to be within limitation-Final assessment order is valid. [S. 144C(13), 154]

 Held that the assessee accepted the final assessment order passed by the Assessing Officer on July 21, 2022. The assessee neither raised objections nor challenged that order but preferred to file a rectification petition under section 154 of the Act. The Assessing Officer rightly rectified the order on October 13, 2022. Therefore, the original assessment order passed by the Assessing Officer on July 21, 2022 was valid in law as it was rectified which was deemed to be considered within the limitation period specified under section 144C(13) of the Act..(AY.2017-18, 2018-19)