Stay on operation of transfer-pricing order; assessment proceedings for 2023-24 restrained pending disposal to preserve status quo.

Ad-interim relief was granted staying the operation of the impugned transfer-pricing order and restraining further assessment proceedings for assessment year 2023-24. The court relied on the contention that assessment was time-barred under the assessment limitation regime as of the statutory cutoff and that a reference to the Transfer Pricing Officer occurred after that date; alleged confusion over issuing authorities and disputed document-production were also noted. Interim measures were directed to preserve the status quo without prejudice to rights, and the stay will operate until further orders.

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Issues: (i) Whether ad-interim relief in the form of a stay on the operation of the impugned order dated 31st December, 2025 under Section 92CA(3) of the Income-tax Act, 1961 and restraint on continuing assessment proceedings for assessment year 2023-24 should be granted pending disposal of the writ petition.

Analysis: The petition alleges that assessment proceedings were time-barred under Section 153(1) of the Income-tax Act, 1961 as of 31st March, 2025 and that a reference to the Transfer Pricing Officer was made after that date; there is also asserted confusion regarding issuing authorities and disputed compliance with document production despite voluminous filings. The Revenue was permitted to file an affidavit in reply and the petitioner to file a rejoinder; interim measures were considered necessary to preserve the status quo without prejudice to the parties' rights while these matters are addressed.

Conclusion: Ad-interim relief is granted in terms of prayer clause (e): the operation of the impugned order dated 31st December, 2025 under Section 92CA(3) of the Income-tax Act, 1961 is stayed and the respondents are restrained from taking any further steps, including continuing assessment proceedings for assessment year 2023-24. The ad-interim relief shall continue until further orders.

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