Transfer Pricing Order Quashed: Invalid Assessment Beyond Time Limit Invalidates Extended Deadline for Final Order Under Sections 143(3) and 144C

ITAT held that the transfer pricing order dated 12.01.2015 merged into the final assessment order dated 20.04.2015 for AY 2011-12 was quashed by CIT(A) as being passed in a non-existent entity's name. Consequently, the extended 12-month time limit for passing the final assessment order was invalid. The assessment order dated 12.05.2015 was beyond the prescribed limitation period of 31.03.2015. The tribunal ruled that the impugned order under section 143(3) read with section 144C was time-barred and liable to be quashed, thereby allowing the assessee's challenge to the order's validity. .....

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