Transfer pricing addition after DRP directions: AO misses s.144C(13) deadline, proceedings time-barred and adjustment ignored for AY 2012-13

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....The dominant issue was whether, after DRP directions, the AO could complete proceedings to give effect to those directions beyond the mandatory time limit under s.144C(13), on the plea that remand proceedings are exempt from the statutory timeline. The court held that s.144C(13) imposes a binding and strict time frame, and where the statute prescribes a manner and timeline, it must be complied with; permitting completion beyond limitation would negate the mandatory provision. Consequently, the pending proceedings to implement the transfer pricing addition were held time-barred, the adjustment was treated as non est, and the total income for AY 2012-13 was directed to be recomputed excluding it - HC....