TP Adjustment - assessment barred by Limitation - Timelines u/s ...

Income Tax

June 20, 2022

TP Adjustment - assessment barred by Limitation - Timelines u/s 92CA, 144C and 153 - the provisions of Sections 144C and 153 are not mutually exclusive, but are rather mutually inclusive. The period of limitation prescribed under Section 153 (2A) or 153 (3) is applicable, when the matters are remanded back irrespective of whether it is to the Assessing Officer or TPO or the DRP, the duty is on the assessing officer to pass orders. - The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within the time limits prescribed. - HC

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TP Adjustment - assessment barred by Limitation - Timelines u/s ...

Income Tax

June 20, 2022

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