Tax Assessment Order Invalidated Due to Missed Deadline; Non-Residents Not Covered by Extended Time Limit.

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....The final assessment order passed by the Assessing Officer u/s 147 read with Section 144C(13) for the Assessment Year 2016-17 is quashed as barred by limitation. Except in cases of reference to the Transfer Pricing Officer, the extended time limit of 12 months for completion of assessment is not available in a case of Non-Resident assessment, even though covered u/s 144C of the Act. As per Section 153(4), the extended time limit of 12 months is not available for Non-Residents. The Assessing Officer ought to have completed the assessment within one year from the end of the financial year in which notice u/s 148 was served, as per Section 153(2). Considering the notice u/s 148 was served in April 2021, the time limit for completing the assess.........