Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
The dominant issue was whether the final assessment order passed under s.143(3) read with s.144C(13) was time-barred under s.153(1) read with s.153(4), including the effect of TOLA notifications. Applying the rule of consistency and following an earlier co-ordinate bench decision, it was held that for AY 2018-19 the statutory time limit to complete assessment expired on 30.09.2021 and TOLA did not extend this period for that year. As the final order was passed after the limitation date, it was held to be barred by limitation and was quashed. - ITAT
The dominant issue was whether the final assessment order passed under s.143(3) read with s.144C(13) was time-barred under s.153(1) read with s.153(4), including the effect of TOLA notifications. Applying the rule of consistency and following an earlier co-ordinate bench decision, it was held that for AY 2018-19 the statutory time limit to complete assessment expired on 30.09.2021 and TOLA did not extend this period for that year. As the final order was passed after the limitation date, it was held to be barred by limitation and was quashed. - ITAT
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