https://www.taxtmi.com/caselaws?id=313616 ITAT Mumbai held that assessment order u/s 143(3) r.w.s. 144C was barred by limitation. For eligible assessee under s. 144C(1), draft order issuance requires variation in returned income prejudicial to assessee's interest. Since foreign non-resident company showed no such variation, AO should have passed assessment order directly within 21 months limitation period under s. 153(1) by 31st December 2016. Assessment order dated 7th February 2017 exceeded limitation period. CIT(A)'s order confirmed and revenue's appeal dismissed. en-us Mon, 30 Jan 2023 00:00:00 +0530 Thu, 25 Apr 2024 06:30:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313616 ITAT Mumbai held that assessment order u/s 143(3) r.w.s. 144C was barred by limitation. For eligible assessee under s. 144C(1), draft order issuance requires variation in returned income prejudicial to assessee's interest. Since foreign non-resident company showed no such variation, AO should have passed assessment order directly within 21 months limitation period under s. 153(1) by 31st December 2016. Assessment order dated 7th February 2017 exceeded limitation period. CIT(A)'s order confirmed and revenue's appeal dismissed. Case-Laws Income Tax Mon, 30 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313616