Limitation period for assessments extended where transfer pricing reference pending; procedural adjustments for searches and requisitions. Amendments to section 153B extend limitation periods where searches under section 132 or requisitions under section 132A coincide with references under section 92CA: where the last authorisation occurred on or after the financial year commencing 1 April 2009 and a 92CA reference was made before 1 July 2012 but no order issued, or is made on/after 1 July 2012, the two year limitation is to be treated as three years. A corresponding rule for other persons under section 153C sets a 36 month or 24 month limitation whichever is later. The Explanation replaces 'six months' with 'one year' and adds an exclusion for the period of certain 144BA references.
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Limitation period for assessments extended where transfer pricing reference pending; procedural adjustments for searches and requisitions.
Amendments to section 153B extend limitation periods where searches under section 132 or requisitions under section 132A coincide with references under section 92CA: where the last authorisation occurred on or after the financial year commencing 1 April 2009 and a 92CA reference was made before 1 July 2012 but no order issued, or is made on/after 1 July 2012, the two year limitation is to be treated as three years. A corresponding rule for other persons under section 153C sets a 36 month or 24 month limitation whichever is later. The Explanation replaces "six months" with "one year" and adds an exclusion for the period of certain 144BA references.
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