Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The ITAT held that the final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.
The ITAT held that the final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.
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