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TMI Blog2014 (5) TMI 590X X X X Extracts X X X X X X X X Extracts X X X X ..... ference order within the time permitted by law - the penalty orders should be separately appealed - orders appear to be prima facie consequent to the draft assessment order - Revenue is directed not to enforce it during the pendency of the reference before the DRP – Decided in favour of Assessee. - W. P. (C) 2276/2014, CM APPL.4775, 4776/2014 - - - Dated:- 30-4-2014 - S. Ravindra Bhat And Vibh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... receipt of the clarification from TPO-II(2), New Delhi, the Assessee is therefore an eligible assessee within the provisions of section 144C of the Act. Since a reference has been made to the TPO due to the international transaction of the Assessee with its Associated Enterprise, the basic conditions under the provisions of 144C(l5) (b) (i) are satisfied and therefore the Assessee becomes an el ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dered by any question of limitation. Likewise, the AO, in the circumstances of the case may make the reference order within the time permitted by law. Further, the Court is of the opinion that the penalty orders should be separately appealed; however, in view of the fact that such orders appear to be prima facie consequent to the draft assessment order in this case, the Revenue is directed not to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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