Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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The assessment order passed u/s 144C(3) was beyond the prescribed period of one month from the end of the month in which the period for filing objections u/s 144C(2) expired. Although the assessee filed objections before the Dispute Resolution Panel beyond the 30-day period, the Assessing Officer was still required to pass the final order within the stipulated timeframe u/s 144C(4). The High Court upheld the Tribunal's decision to set aside the final assessment order as being time-barred, rejecting the Revenue's argument that the assessee cannot take advantage of its own delay in filing objections. The statutory language of Section 144C(4) is unambiguous, and the Assessing Officer's failure to comply with the time limit renders the order invalid, irrespective of the assessee's delay.
The assessment order passed u/s 144C(3) was beyond the prescribed period of one month from the end of the month in which the period for filing objections u/s 144C(2) expired. Although the assessee filed objections before the Dispute Resolution Panel beyond the 30-day period, the Assessing Officer was still required to pass the final order within the stipulated timeframe u/s 144C(4). The High Court upheld the Tribunal's decision to set aside the final assessment order as being time-barred, rejecting the Revenue's argument that the assessee cannot take advantage of its own delay in filing objections. The statutory language of Section 144C(4) is unambiguous, and the Assessing Officer's failure to comply with the time limit renders the order invalid, irrespective of the assessee's delay.
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