2021 (12) TMI 944

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....39;BLE MR. JUSTICE NAVIN CHAWLA Petitioner Through Mr. Salil Kapoor, Mr. Sumit Lalchandani, Ms. Ananya Kapoor, Ms. Soumya Singh, Mr. Sanat Kapoor, Advs.   Respondent Through Mr. Sanjay Kumar, Sr. SC, Ms. Easha Kadiyan, Adv.   NAVIN CHAWLA, J. (Oral) 1. This petition has been filed by the petitioner challenging the Final Assessment Order dated 30.06.2021 passed by the respondent under....

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....961/- (Rupees twenty crore twenty-two lakh ninety-two thousand nine hundred sixty-one) on account of transfer pricing adjustment for international transactions qua the issues of import of goods and interests on External Commercial Borrowings ('ECBs'). Based thereon, the respondent issued a Draft Assessment Order dated 21.04.2021 under Section 144C of the Act. Though Section 144C(2) of the Act allo....

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.... passed by the Supreme Court in Suo Motu Writ Petition (Civil) No. 03 of 2020, In Re: Cognizance for Extension of Limitation and CBDT Circular No. 10 of 2021 dated 25.05.2021 to contend that the period of limitation for filing of the objections stood extended and therefore, the objections having been filed within the time permitted, the Impugned Final Assessment Order is without jurisdiction. The ....

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....hin its right to complete the assessment on the basis of the Draft Assessment Order and therefore, no fault can be found in the Impugned Final Assessment Order. 5. Today, the learned counsel for the petitioner has submitted that the DRP has, in fact, finally heard the objections on merit on 30.11.2021. In support, he has produced before us an e-mail dated 30.11.2021 from the DCIT, Secretary (DRP-....