Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
The Appellate Tribunal considered the validity of assessment proceedings u/s 144C, focusing on the period of limitation. The assessee argued that u/s 153(4), an extended 12-month period for assessment completion applies only when a reference u/s 92CA(1) is made to the Transfer Pricing Officer (TPO) during assessment or re-assessment. The Tribunal agreed, noting that the extended time limit is not available for Non-Resident assessments u/s 144C. As the assessment notice was issued on 30.03.2021, the assessment should have been completed by 31/03/2022. Since the final assessment order was passed on 12.01.2023, it was deemed barred by limitation. The Tribunal allowed the assessee's appeal.
The Appellate Tribunal considered the validity of assessment proceedings u/s 144C, focusing on the period of limitation. The assessee argued that u/s 153(4), an extended 12-month period for assessment completion applies only when a reference u/s 92CA(1) is made to the Transfer Pricing Officer (TPO) during assessment or re-assessment. The Tribunal agreed, noting that the extended time limit is not available for Non-Resident assessments u/s 144C. As the assessment notice was issued on 30.03.2021, the assessment should have been completed by 31/03/2022. Since the final assessment order was passed on 12.01.2023, it was deemed barred by limitation. The Tribunal allowed the assessee's appeal.
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