Validity of Final Assessment Order u/s 144C(13) Challenged Over Transfer Pricing and Limitation Period Issues.

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....Transfer pricing - Validity of the final assessment order passed u/s 144C(13) - Period of limitation - In the instant case, the manual final assessment order is dated 24.01.2017. The final assessment order has dispatch seal also. There is nothing on record to show that the final assessment order has not been dispatched on the said date. The demand was uploaded to CPC portal on 13.03.2017, so the CPC shows the date as the date of order. The CPC will always show the date on which the demand is fed into. The entire order is not uploaded, but only the demand was uploaded in the CPC. - AT....