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<h1>Stay on operation of transfer-pricing order; assessment proceedings for 2023-24 restrained pending disposal to preserve status quo.</h1> Ad-interim relief was granted staying the operation of the impugned transfer-pricing order and restraining further assessment proceedings for assessment ... Validity of order passed u/s 92CA(3) as barred by limitation - reference to the TPO - ad-interim relief in the form of a stay on the operation - it is the case of the Petitioner that once the Assessment proceedings were itself barred on 31st March, 2025, there was no question of making any reference to the TPO after the said date. HELD THAT: - The Court, observing the factual position and without prejudice to the rights and contentions of the parties, granted ad-interim relief staying the operation of the impugned order passed under Section 92CA(3) and restrained the Respondents from taking further steps, including continuing assessment proceedings for the assessment year 2023-24. The Court directed the Revenue to file an Affidavit in Reply by a specified date and permitted the Petitioner to file a rejoinder, and listed the matter for further hearing on the specified date. [Paras 8, 9] Ad-interim stay granted of the impugned order dated 31st December, 2025 and respondents restrained from proceeding with assessment proceedings for assessment year 2023-24; matter listed for further consideration. Final Conclusion: The High Court granted ad-interim relief by staying the operation of the impugned Section 92CA(3) order and restraining further assessment steps in respect of assessment year 2023-24, directed filing of affidavits by the parties, and listed the matter for further hearing. 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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