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The final assessment order passed by the Assessing Officer u/s 147 read with Section 144C(13) for the Assessment Year 2016-17 is quashed as barred by limitation. Except in cases of reference to the Transfer Pricing Officer, the extended time limit of 12 months for completion of assessment is not available in a case of Non-Resident assessment, even though covered u/s 144C of the Act. As per Section 153(4), the extended time limit of 12 months is not available for Non-Residents. The Assessing Officer ought to have completed the assessment within one year from the end of the financial year in which notice u/s 148 was served, as per Section 153(2). Considering the notice u/s 148 was served in April 2021, the time limit for completing the assessment u/s 147 was available up to 31.03.2023. Hence, the final assessment order dated 08.01.2024 is clearly barred by limitation and liable to be quashed.
The final assessment order passed by the Assessing Officer u/s 147 read with Section 144C(13) for the Assessment Year 2016-17 is quashed as barred by limitation. Except in cases of reference to the Transfer Pricing Officer, the extended time limit of 12 months for completion of assessment is not available in a case of Non-Resident assessment, even though covered u/s 144C of the Act. As per Section 153(4), the extended time limit of 12 months is not available for Non-Residents. The Assessing Officer ought to have completed the assessment within one year from the end of the financial year in which notice u/s 148 was served, as per Section 153(2). Considering the notice u/s 148 was served in April 2021, the time limit for completing the assessment u/s 147 was available up to 31.03.2023. Hence, the final assessment order dated 08.01.2024 is clearly barred by limitation and liable to be quashed.
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