VMware Software India P. Ltd. v. Dy. CIT (2022)98 ITR 219 (Bang) (Trib)

S. 144C : Reference to dispute resolution panel-Transfer pricing-Assessing Officer to pass final order from end of month in which direction received from Dispute Resolution Panel-Order not barred by limitation.[S. 92C, 144C(13)]

Held, that the final assessment order was dated January 24, 2017. There was nothing on record to show that the final assessment order had not been dispatched on the said date. The demand was uploaded to the portal on March 13, 2017, so the portal showed the date as the date of order. The entire order was not uploaded, but only the demand was uploaded. Therefore, the final assessment order was dispatched within the time limit prescribed and was not barred by limitation. (AY. 2012-13)