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The ITAT held that the TPO's order under s.92CA(3) is time-barred by one day and therefore invalid. The tribunal found the assessment limitation under s.153(1) expired on 31 Mar 2013, so the statutory 60-day cutoff for issuing an order under s.92CA(3A) lapsed on 29 Jan 2013; reliance on a departmental circular using the phrase "two months" could not supplant the statutory "60 days" calculation. Applying the statutory timeline strictly, the TPO's s.92CA order was barred by limitation and set aside, and the assessee's appeal was allowed.
The ITAT held that the TPO's order under s.92CA(3) is time-barred by one day and therefore invalid. The tribunal found the assessment limitation under s.153(1) expired on 31 Mar 2013, so the statutory 60-day cutoff for issuing an order under s.92CA(3A) lapsed on 29 Jan 2013; reliance on a departmental circular using the phrase "two months" could not supplant the statutory "60 days" calculation. Applying the statutory timeline strictly, the TPO's s.92CA order was barred by limitation and set aside, and the assessee's appeal was allowed.
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