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2022 (10) TMI 1053 - HC - Income TaxTP adjustments - Period of limitation for proceedings before the DRP - HELD THAT:- As in this case, the order of the Tribunal having been received by the officer as early as in 2016, the limitation for passing of the order expires on or before 31.03.2017 and the proceedings under the impugned order are thus clearly barred by limitation. As to acquiescence of the petitioner, reject the submission of the respondents for the reason that once an order is established to be beyond limitation, mere co-operation of the party in the proceedings would not extend the same. In fact, even as on 29.01.2020 when the petitioner had written to the DRP, limitation had long expired and thus there is no merit in this submission of the respondents. The impugned order is set aside and this writ petition is allowed.
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