Ariba India Private Limited vs. ACIT

Parties Involved

Facts Summary

The assessee, Ariba India Private Limited, filed its return of income for the assessment year 2011-12 declaring a total income of Rs. 1,27,46,780/-. The case was selected for scrutiny, and a draft assessment order was passed proposing adjustments and additions amounting to Rs. 1,93,37,357/- and Rs. 82,92,871/- respectively. The assessee filed objections before the Dispute Resolution Panel (DRP), which upheld the adjustments and additions. The final assessment order was passed on 29.01.2016 determining the total income at Rs. 4,03,77,010/-. Aggrieved by this order, the assessee filed an appeal before the Tribunal, which restored the matter to the Transfer Pricing Officer (TPO) and Assessing Officer (AO). Subsequent orders and objections led to the final assessment order on 31.03.2024, which the assessee now appeals against, primarily on the grounds that the order is time-barred and invalid.…

Legal Issues

• 1. Whether the final assessment order is bad in law and void ab initio since it was passed beyond the limitation prescribed under section 144C(13).

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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