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    <title>2023 (5) TMI 1203 - ITAT MUMBAI</title>
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    <description>The transfer pricing order was held time-barred because section 92CA(3A), read with section 153, required the TPO to pass the order by 29 January 2014, but it was issued on 30 January 2014. Applying the mandatory nature of the statutory time limit, the order was treated as legal force and quashed. Foreign tax credit and TDS credit claims depended on factual verification, so those issues were remitted to the Assessing Officer for fresh consideration after examination of the supporting records and opportunity of hearing. The interest grounds were consequential and required no separate adjudication.</description>
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