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2022 (3) TMI 1510 - AT - Income TaxValidity of order u/s 92CA(3) - period of limitation - Time limit for completion of assessments and reassessments - protection u/s. 292BB - HELD THAT:- Hon’ble Delhi Tribunal in case of Honda Trading Corporation Vs. DCIT [2015 (9) TMI 846 - ITAT DELHI] held that the time limit specified u/s 92CA(3A) is mandatory and not directory and therefore the Ld.TPO is bound by the time limit for passing of the order u/s 92CA (3) of the Act. Thus we hold that the order of the Ld.TPO passed on 30.01.2015 is barred by limitation and liable to be quashed. Therefore, consequently, the proposed addition on account of transfer pricing adjustment amounting to does not survive.
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