Validity of Transfer Pricing Notice u/s 92CA(2)
This query is : Resolved
09 April 2025
We received Notice u/s. 92CA(2) of the Income Tax Act, 1961 – Computation of Arm's Length Price-
Assessment Year 2023-24 on 07/04/2025.
My question is, wheather this notice is considered as time barred notice or not. Because it is issued after compltion of 2 years from the end of relevent financial year i.e FY 2022-23
I think Due date for issuance of this notice is 31/03/2025. Am I correct ?
Assessment Year 2023-24 on 07/04/2025.
My question is, wheather this notice is considered as time barred notice or not. Because it is issued after compltion of 2 years from the end of relevent financial year i.e FY 2022-23
I think Due date for issuance of this notice is 31/03/2025. Am I correct ?
09 April 2025
Yes, date of issuance also matters..
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09 April 2025
Thank You sir for your response,
Can I consider this notice as time barred and respond accordingly ?
Can I consider this notice as time barred and respond accordingly ?
09 April 2025
No.
In CIT vs. Dey Brothers, the court indeed highlighted an important aspect of legal proceedings regarding the service of notice. One key point that the court stressed was that the issue date of the notice is crucial for determining the timeline within which legal actions must be taken.
In CIT vs. Dey Brothers, the court indeed highlighted an important aspect of legal proceedings regarding the service of notice. One key point that the court stressed was that the issue date of the notice is crucial for determining the timeline within which legal actions must be taken.
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