https://www.taxtmi.com/caselaws?id=450939 The ITAT Mumbai held that a TPO order passed under section 92CA(3) was time-barred as it was not completed within 60 days prior to the limitation period under section 153. The TPO order should have been passed by 31/10/2019, considering the assessment completion deadline of 31/12/2019 (21 months plus 12 months extension for TP reference). Consequently, the TPO order was quashed as invalid. Without a valid TPO order, no transfer pricing adjustment could be sustained, making the assessee ineligible for section 144C proceedings. The draft assessment order became legally invalid, and all consequential proceedings failed. The assessee's appeal was allowed. en-us Wed, 13 Mar 2024 00:00:00 +0530 Mon, 05 Aug 2024 13:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450939 The ITAT Mumbai held that a TPO order passed under section 92CA(3) was time-barred as it was not completed within 60 days prior to the limitation period under section 153. The TPO order should have been passed by 31/10/2019, considering the assessment completion deadline of 31/12/2019 (21 months plus 12 months extension for TP reference). Consequently, the TPO order was quashed as invalid. Without a valid TPO order, no transfer pricing adjustment could be sustained, making the assessee ineligible for section 144C proceedings. The draft assessment order became legally invalid, and all consequential proceedings failed. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450939