Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Sections 144C and 153 require harmonious construction when determining limitation for a final assessment made pursuant to DRP directions. The non-obstante clause in section 144C(13) does not displace the outer time limit under section 153; the final assessment must therefore be completed within that prescribed limitation period. Applying the binding High Court precedent, the ITAT treated the final assessment for Assessment Year 2018-19 as time-barred and quashed it. Merits grounds remained open, with liberty to seek revival if a Supreme Court decision requires modification.
Sections 144C and 153 require harmonious construction when determining limitation for a final assessment made pursuant to DRP directions. The non-obstante clause in section 144C(13) does not displace the outer time limit under section 153; the final assessment must therefore be completed within that prescribed limitation period. Applying the binding High Court precedent, the ITAT treated the final assessment for Assessment Year 2018-19 as time-barred and quashed it. Merits grounds remained open, with liberty to seek revival if a Supreme Court decision requires modification.
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