https://www.taxtmi.com/caselaws?id=753662 ITAT Hyderabad held that assessment proceedings under section 144C are subject to limitation period under section 153(2) of 12 months from end of financial year when notice under section 148 was served. The extended 12-month period under section 153(4) applies only when reference to TPO is made under section 92CA(1), not in non-resident assessments without TPO reference. Since notice was issued on 30.03.2021 and assessment order was passed on 12.01.2023, it exceeded the limitation period ending 31.03.2022. Assessment order was quashed as time-barred. Assessee's appeal allowed. en-us Mon, 03 Jun 2024 00:00:00 +0530 Mon, 23 Feb 2026 10:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753662 ITAT Hyderabad held that assessment proceedings under section 144C are subject to limitation period under section 153(2) of 12 months from end of financial year when notice under section 148 was served. The extended 12-month period under section 153(4) applies only when reference to TPO is made under section 92CA(1), not in non-resident assessments without TPO reference. Since notice was issued on 30.03.2021 and assessment order was passed on 12.01.2023, it exceeded the limitation period ending 31.03.2022. Assessment order was quashed as time-barred. Assessee's appeal allowed. Case-Laws Income Tax Mon, 03 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753662