Time limits for GAAR notices: Commissioner barred from late directions or references after specified post compliance periods. Time limits under section 144BA and rule 10UB/10UC fix procedural bars: the Commissioner cannot issue directions under section 144BA(3) later than one month from the end of the month in which compliance with the section 144BA(2) notice occurs, nor refer matters to the Approving Panel under section 144BA(4) later than two months from the end of the month in which the assessee's final submission is received. The Commissioner must issue directions to the assessing officer in Form No.3CEH within one month from the end of the month of receipt of a reference under rule 10UB(4)(i), and within two months from the end of the month of receipt of the assessee's final submission under rule 10UB(4)(ii).