Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
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Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
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