Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
The dominant issue was whether the time-limit for a final assessment order under section 143(3) read with sections 144C(13) and 144B must be computed under section 153(1) read with section 153(4), or under section 144C(13). The Tribunal held that statutory limitation is governed by section 153(1) read with section 153(4), applying consistency with its earlier view, and computed the deadline as 31.12.2020. Since the final assessment order was passed on 12.01.2022, it was beyond the prescribed period; the order was held time-barred and quashed. - ITAT
The dominant issue was whether the time-limit for a final assessment order under section 143(3) read with sections 144C(13) and 144B must be computed under section 153(1) read with section 153(4), or under section 144C(13). The Tribunal held that statutory limitation is governed by section 153(1) read with section 153(4), applying consistency with its earlier view, and computed the deadline as 31.12.2020. Since the final assessment order was passed on 12.01.2022, it was beyond the prescribed period; the order was held time-barred and quashed. - ITAT
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