2025 (8) TMI 1860

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ee : Shri Majoj Pardarsani, AR Ms. Deepanshi Agarwal, AR For the Revenue : Shri Amit Kumar Singh, Sr. DR ORDER PER M. BALAGANESH, A. M.: 1. The Assessee CNH Industrial (India) Pvt. Ltd, (hereinafter referred to as 'assessee) by filing the present appeal sought to set aside the impugned order dated 03.12.2024 passed by the Assessing Officer (AO) under section 144C r.w.s. 144C(13) r.w.s.....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e the ld Dispute Regulation Panel (DRP). The ld DRP issued directions u/s 144C(5) of the Act on 28.09.2024. The assessee received the said direction by email from ld DRP on 28.09.2024. The ld TPO passed an order giving effect to the directions of the ld DRP on 24.10.2024. There is absolutely no dispute with regard to the dates on which the aforesaid orders were passed and served on both the partie....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....mited V. ACIT in ITA No. 1628/Del/2022, Syniverse Technologies Services (India) Pvt Ltd in ITA No. 391/Del/2022 dated 21.08.2024, Canon India Ltd in ITA No. 1940/Del/2024, among others. In view of the aforesaid observations and respectfully following the judicial precedents, we hold that the final assessment order passed u/s 144 read with section 144C(13) on 03.12.2024 is barred by limitation. Acc....