Transfer Pricing timelines clarified: remand time limits require DRP, TPO and Assessing Officer to complete proceedings within statutory windows.

Clarifies interplay of remand and limitation in transfer pricing disputes: when matters are remanded to the assessing officer, TPO or DRP, the remand triggers applicable statutory time limits and those authorities must complete proceedings within those prescribed windows; effectassessing officer must pass final orders within the stipulated period even if the DRP or TPO does not conclude within its internal timeline. Clarifies DRP must issue hearings and directions within nine months and that remand requires issuance of a de novo draft order by the assessing officer for transfer pricing matters; effectthe outer limitation applies to final orders, not drafts, so proceedings must be completed within the prescribed outer periods.

---

---

The Supreme Court, with Hon'ble Mr. Justice M.R. Shah and Hon'ble Mr. Justice C.T. Ravikumar, heard the case. The Petitioner was represented by Mr. N. Venkataraman, ASG, and others. The Respondent did not have representation. The Court condoned the delay, issued notice, granted leave, and scheduled the case to be heard along with C.A. No. 6755/2018.

---