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HC upheld the petition, declaring assessment notices for AY 2010-11 time-barred under Section 153(3). The Tribunal's order passed after 01 April 2019 extended the limitation period from 9 to 12 months. Calculating 12 months from the Tribunal's 21 October 2020 order revealed the jurisdictional authority expired on 21 October 2021. Consequently, the HC quashed the assessment notices dated 06 March 2023 and 19 March 2023 as legally impermissible, effectively invalidating any proposed transfer pricing adjustments beyond the prescribed statutory limitation.
HC upheld the petition, declaring assessment notices for AY 2010-11 time-barred under Section 153(3). The Tribunal's order passed after 01 April 2019 extended the limitation period from 9 to 12 months. Calculating 12 months from the Tribunal's 21 October 2020 order revealed the jurisdictional authority expired on 21 October 2021. Consequently, the HC quashed the assessment notices dated 06 March 2023 and 19 March 2023 as legally impermissible, effectively invalidating any proposed transfer pricing adjustments beyond the prescribed statutory limitation.
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