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| The Tax Publishers2020 TaxPub(DT) 2920 (Bang-Trib) INCOME TAX ACT, 1961
Section 144C
CIT(A) rejected contentions of assessee on all issues relating to transfer pricing and passed an order upholding order passed by TPO on the basis that assessee had not filed objections to draft assessment order before DRP, matter was remanded to CIT(A) for adjudication because in terms of section 144C, assessee had an option either to file objection before DRP against the draft assessment order or obtain a final assessment order and challenge the same before CIT(A).
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Assessment - Transfer pricing - Assessee challenged order before CIT(A) - CIT(A) rejected contention of assessee on the gorund of no objection raised before DRP
CIT(A) rejected contentions of assessee on all issues relating to transfer pricing and passed an order upholding order passed by TPO on the basis that assessee had not filed objections to draft assessment order before DRP under section 144C and therefore, assessee was precluded from raising objection against final assessment order before him. Held: In terms of section 144C, assessee had an option either to file objection before DRP against the draft assessment order or obtain a final assessment order and challenge the same before CIT(A) since CIT(A) has not decided the appeal on merits, matter was remanded to CIT(A) for adjudication.
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2013-14
IN THE ITAT, BANGALORE BENCH
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