https://www.taxtmi.com/caselaws?id=783742 A transfer-pricing eligible assessee may raise an additional pure question of law even if omitted from the memorandum of appeal, because Rule 11 of the ITAT Rules permits such a ground with leave and after hearing the other side; the objection to admission was therefore rejected. On limitation, the Tribunal held that completion of the final assessment remains governed by sections 153(1) and 153(4) of the Income-tax Act, and section 144C(13) does not independently enlarge time. It further held that the pandemic-related extension of limitation did not apply to the tax authority's order, so the assessment order passed on 25.07.2024 was time-barred and liable to be quashed. en-us Fri, 12 Dec 2025 00:00:00 +0530 Mon, 22 Dec 2025 07:49:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783742 A transfer-pricing eligible assessee may raise an additional pure question of law even if omitted from the memorandum of appeal, because Rule 11 of the ITAT Rules permits such a ground with leave and after hearing the other side; the objection to admission was therefore rejected. On limitation, the Tribunal held that completion of the final assessment remains governed by sections 153(1) and 153(4) of the Income-tax Act, and section 144C(13) does not independently enlarge time. It further held that the pandemic-related extension of limitation did not apply to the tax authority's order, so the assessment order passed on 25.07.2024 was time-barred and liable to be quashed. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783742