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2018 (7) TMI 822 - ITAT DELHIReference matter to the TPO for determining the ALP of the international transaction u/s 153 (1) - period of limitation - Held that:- Since the facts of the instant case are identical to the facts of the case decided by the Tribunal in the case of Calance Software Pvt. Ltd. (2018 (3) TMI 1310 - ITAT DELHI) and since the time limit for issue of the order by the Assessing Officer in case of the TPO reference u/s 153 (1) of the IT Act expired on 31.12.2009, therefore, we hold that impugned assessment order is bad in law and is barred by limitation. Ground raised by the assessee is accordingly allowed.
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