Time limits for search-based assessments are a self-contained code; extension applies only with a transfer pricing reference, otherwise late orders ar...
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
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