Court Rules Transfer Pricing Adjustment Order Beyond Limitation Period; Cooperation Doesn't Extend Deadline, Says Court.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP adjustments - Period of limitation for proceedings before the DRP - As to acquiescence of the petitioner, reject the submission of the respondents for the reason that once an order is established to be beyond limitation, mere co-operation of the party in the proceedings would not extend the same. In fact, even as on 29.01.2020 when the petitioner had written to the DRP, limitation had long expired and thus there is no merit in this submission of the respondents. - HC....