https://www.taxtmi.com/caselaws?id=783893 Section 144C(13) mandates that the AO give effect to DRP directions within the statutorily prescribed timeline; this time limit applies even where the matter is treated as involving remand-type proceedings. Applying the settled rule that statutory requirements must be complied with strictly and cannot be waived or ignored, the HC rejected the revenue's contention that the limitation under s.144C(13) is inapplicable in such cases. As the proceedings to give effect to the DRP directions had exceeded the permissible period, they were held barred by limitation; consequently, the transfer pricing adjustment was declared non est and the AO was directed to recompute total income for AY 2012-2013 excluding that adjustment. en-us Tue, 16 Dec 2025 00:00:00 +0530 Wed, 24 Dec 2025 07:51:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783893 Section 144C(13) mandates that the AO give effect to DRP directions within the statutorily prescribed timeline; this time limit applies even where the matter is treated as involving remand-type proceedings. Applying the settled rule that statutory requirements must be complied with strictly and cannot be waived or ignored, the HC rejected the revenue's contention that the limitation under s.144C(13) is inapplicable in such cases. As the proceedings to give effect to the DRP directions had exceeded the permissible period, they were held barred by limitation; consequently, the transfer pricing adjustment was declared non est and the AO was directed to recompute total income for AY 2012-2013 excluding that adjustment. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783893