Assessment Order Invalidated for Exceeding Time Limit; Draft Order u/s 144C(1) Unjustified, Final Order Time-Barred.

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....Validity of assessment order passed u/s 153(1) - Period of limitation - In this case, since, the Assessing Officer cannot invoke jurisdiction u/s.144C(1) and pass draft assessment order, question of extended 12 months period cannot be given to the Assessing Officer. Therefore, we are of the considered view that final assessment order passed by the Assessing Officer u/s.144C(3) r.w.s 143(3) of the Act, dated 28.02.2017 is barred by limitation, because time limit available for completion of assessment u/s.143(3) is 31.12.2016. - AT....