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 a final assessment order passed under section 143(3) read with sections 144C(13) and 144B is subject to the outer limitation prescribed under sections 153(1) and 153(4). Relying on binding judicial precedents, it was held that the statutory upper time limit under section 153(1), as extended by section 153(4) where a transfer pricing reference is made, governs such final assessment orders, and any order passed beyond that period is time-barred and void. Since the impugned final assessment order was issued after expiry of the extended limitation period, it was quashed and the appeal was allowed. - ITAT
The dominant issue was whether a final assessment order passed under section 143(3) read with sections 144C(13) and 144B is subject to the outer limitation prescribed under sections 153(1) and 153(4). Relying on binding judicial precedents, it was held that the statutory upper time limit under section 153(1), as extended by section 153(4) where a transfer pricing reference is made, governs such final assessment orders, and any order passed beyond that period is time-barred and void. Since the impugned final assessment order was issued after expiry of the extended limitation period, it was quashed and the appeal was allowed. - ITAT
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