ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD
In the result, appeal filed by the assessee is partly allowed for statistical purposes
ITA 392/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18
Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)
For Appellant: Shri Mukesh Patel, Shri Ajit KumarFor Respondent: Shri Prathvi Raj Meena, CIT.DR
Section 153(4)Section 153CSection 35Section 35(1)(i)Section 35(1)(iv)Section 92CSection 92C(2)
Transfer Pricing Officer (TPO) has erred in law and on facts in exceeding the jurisdiction by passing the TP Order under Section 92CA(3) of the Income-tax Act, 1961 (the Act) beyond the mandatorily prescribed time limit as per Section 92CA(3A) read with Section 153(4) of the Act, thereby making the TP Order barred by limitation