https://www.taxtmi.com/caselaws?id=752098 The ITAT Mumbai held that the TPO's order dated 01.11.2019 was barred by limitation under section 92CA(3) as it was passed beyond the mandatory time limit of 31.10.2019. Following precedents from Madras HC including Saint Gobain India case, the tribunal ruled that the time period under section 92CA(3) is mandatory despite using the word "may." Consequently, the invalid transfer pricing order rendered the draft assessment order and final assessment order dated 27.03.2021 invalid, as the AO lacked jurisdiction under section 144C. The assessee's additional grounds were allowed and all orders were quashed. en-us Tue, 30 Apr 2024 00:00:00 +0530 Fri, 03 May 2024 07:11:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752098 The ITAT Mumbai held that the TPO's order dated 01.11.2019 was barred by limitation under section 92CA(3) as it was passed beyond the mandatory time limit of 31.10.2019. Following precedents from Madras HC including Saint Gobain India case, the tribunal ruled that the time period under section 92CA(3) is mandatory despite using the word "may." Consequently, the invalid transfer pricing order rendered the draft assessment order and final assessment order dated 27.03.2021 invalid, as the AO lacked jurisdiction under section 144C. The assessee's additional grounds were allowed and all orders were quashed. Case-Laws Income Tax Tue, 30 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752098