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2024 (1) TMI 150 - AT - Income TaxValidity of TP order u/s 92CA(3) beyond the time limit prescribed u/s 92CA (3A) r.w.s. 153 - counting of 60 days for passing TPO order - HELD THAT:- 60 days period as per the provisions of section 153(1) read with section 92C(3) expires on 30/03/2021 and therefore, the transfer pricing order should have been passed one day prior i.e.by 29/01/2021. In assessee's case it is further noticed that the TPO has actually passed the order on 30/01/2021. Therefore, relying on the decision in the case of Pfizer Healthcare India Pvt Ltd [2022 (4) TMI 808 - MADRAS HIGH COURT] we are of the considered view that the impugned order passed by the TPO is barred by limitation and, therefore, liable to be quashed. Assessee appeal allowed.
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