Limitation period extended: thirty-three month assessment window replaces two years where search or requisition triggers transfer pricing reference. The amendment provides that where the last authorisation for search or requisition occurred in or after the financial year beginning 1 April 2005 and a transfer pricing reference was pending or made on or after the operative date, the two year limitation is to be read as thirty-three months; for an other person receiving seized or requisitioned materials the limitation is thirty-three months from the end of the financial year of the last authorisation or twenty-one months from the end of the financial year in which materials are handed over to the Assessing Officer, whichever is later.
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Provisions expressly mentioned in the judgment/order text.
Limitation period extended: thirty-three month assessment window replaces two years where search or requisition triggers transfer pricing reference.
The amendment provides that where the last authorisation for search or requisition occurred in or after the financial year beginning 1 April 2005 and a transfer pricing reference was pending or made on or after the operative date, the two year limitation is to be read as thirty-three months; for an other person receiving seized or requisitioned materials the limitation is thirty-three months from the end of the financial year of the last authorisation or twenty-one months from the end of the financial year in which materials are handed over to the Assessing Officer, whichever is later.
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