Limitation for transfer pricing final assessment under section 144C and 153: orders passed beyond limitation quashed.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The dispute concerned whether the limitation for passing a final assessment under the transfer pricing assessment procedure must be measured solely by the timeline in the specific transfer pricing provision or by reference to both that provision and the general assessment limitation provision; the tribunal concluded that the provisions are mutually inclusive and overlapping, and limitation must be determined with reference to both provisions, resulting in final assessment orders issued beyond the combined limitation period being without jurisdiction and quashed for the specified assessment years.....