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    <title>2025 (12) TMI 1582 - ITAT DELHI</title>
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    <description>The dominant issue was whether the assessment order was time-barred under s.153(1) due to an allegedly belated reference to the TPO. The Tribunal held that for AY 2019-20 the assessment had to be completed by 30.09.2021, but the TPO order was made only pursuant to a reference letter dated 28.01.2022; applying the ratio of an HC decision on limitation in transfer pricing references, the order passed under s.143(3) r.w.s. 144B dated 28.03.2022 was beyond the statutory time limit and therefore void. The assessment was held invalid and the appeal was allowed in favour of the assessee.</description>
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    <pubDate>Tue, 23 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1582 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784042</link>
      <description>The dominant issue was whether the assessment order was time-barred under s.153(1) due to an allegedly belated reference to the TPO. The Tribunal held that for AY 2019-20 the assessment had to be completed by 30.09.2021, but the TPO order was made only pursuant to a reference letter dated 28.01.2022; applying the ratio of an HC decision on limitation in transfer pricing references, the order passed under s.143(3) r.w.s. 144B dated 28.03.2022 was beyond the statutory time limit and therefore void. The assessment was held invalid and the appeal was allowed in favour of the assessee.</description>
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