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ITAT upheld CIT(A)'s decision that assessment order under s.143(3) r.w.s. 144C(3) r.w.s. 144B was time-barred. TPO reference under s.92CA(1) was made on 13.09.2021, with TPO order under s.92CA(3) issued on 28.01.2022. Per s.153(4), deadline extended to 31.03.2022, but assessment order was passed on 30.09.2022, beyond statutory limitation period. Without CBDT extension or statutory provision extending timeline, assessment order was invalid. Jurisdictional issue of limitation decided against Revenue, confirming assessment as time-barred.
ITAT upheld CIT(A)'s decision that assessment order under s.143(3) r.w.s. 144C(3) r.w.s. 144B was time-barred. TPO reference under s.92CA(1) was made on 13.09.2021, with TPO order under s.92CA(3) issued on 28.01.2022. Per s.153(4), deadline extended to 31.03.2022, but assessment order was passed on 30.09.2022, beyond statutory limitation period. Without CBDT extension or statutory provision extending timeline, assessment order was invalid. Jurisdictional issue of limitation decided against Revenue, confirming assessment as time-barred.
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