ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

ITA 162/AHD/2021Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17Bench: SHRI WASEEM AHMED (Accountant Member), Ms. MADHUMITA ROY (Judicial Member)41 pages
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What did the Tribunal hold?

The Tribunal held that the TPO's order was passed beyond the limitation period prescribed under Section 92CA(3A) read with Section 153 of the Act. Consequently, the final assessment order was also deemed time-barred and quashed.

What were the facts?

The assessee's appeal challenges the validity of the Transfer Pricing Officer's (TPO) order and the subsequent assessment order. The core issue is whether these orders were passed within the prescribed time limits under the Income Tax Act.

What were the issues?

The primary legal issue was whether the Transfer Pricing Officer's order and the subsequent assessment order were passed within the statutory time limits, rendering them valid.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 92CA(3),Section 92CA(3A),Section 153,Section 153(4)

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Cases cited in this judgment(16)Show list

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Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: SHRI WASEEM AHMED&

For Appellant: Ms. Saumya Pandey Jain
Hearing: 12/03/2024

PER Ms. MADHUMITA ROY - JM: The instant appeal filed by the assessee is directed against the order dated 30.04.2021 passed by the Additional / Joint / Deputy / Assistant Commissioner of Income Tax, National e-

ITA No. 162/Ahd/2021 (Zydus Lifesciences Ltd. vs. DCIT) A.Y.– 2016-17 - 2 – Assessment Centre, Delhi under Secti

The order continues below.

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