<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2024 (12) TMI 629 - ITAT AHMEDABAD</title>
    <link>https://www.taxtmi.com/caselaws?id=763049</link>
    <description>ITAT Ahmedabad held that the Transfer Pricing Officer&#039;s order dated 1st November 2019 was invalid as it was issued beyond the mandatory 60-day limitation period prescribed under Section 92CA(3A) read with Section 153 of the Income Tax Act. The TPO was required to issue the order by 31st October 2019, being 60 days prior to the assessment completion due date. The tribunal ruled that this limitation is mandatory and cannot be breached, rendering the belated TP order unenforceable. Consequently, the Assessing Officer was not entitled to extended time under Section 153(4) for completing the assessment. The case was decided in favor of the assessee.</description>
    <language>en-us</language>
    <pubDate>Thu, 30 May 2024 00:00:00 +0530</pubDate>
    <lastBuildDate>Thu, 12 Dec 2024 08:55:56 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=782209" rel="self" type="application/rss+xml"/>
    <item>
      <title>2024 (12) TMI 629 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=763049</link>
      <description>ITAT Ahmedabad held that the Transfer Pricing Officer&#039;s order dated 1st November 2019 was invalid as it was issued beyond the mandatory 60-day limitation period prescribed under Section 92CA(3A) read with Section 153 of the Income Tax Act. The TPO was required to issue the order by 31st October 2019, being 60 days prior to the assessment completion due date. The tribunal ruled that this limitation is mandatory and cannot be breached, rendering the belated TP order unenforceable. Consequently, the Assessing Officer was not entitled to extended time under Section 153(4) for completing the assessment. The case was decided in favor of the assessee.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Thu, 30 May 2024 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=763049</guid>
    </item>
  </channel>
</rss>