https://www.taxtmi.com/caselaws?id=753609 The ITAT Chennai held that a Transfer Pricing Order passed under Section 92CA(3) was barred by limitation. The TPO issued the order on 01.11.2019 for AY 2016-17, but Section 92CA(3A) requires such orders to be passed at least 60 days before the assessment limitation period expires. Since the assessment had to be completed by 31.12.2019, the TPO order should have been passed by 31.10.2019 or earlier. Following the Madras HC decision in Pfizer Healthcare, the tribunal ruled the TP proceedings were time-barred, making the assessee ineligible under Section 144C(15)(b), and consequently the assessment should have been completed within 33 months under Section 153(1). The appeal was allowed on legal grounds. en-us Mon, 03 Jun 2024 00:00:00 +0530 Thu, 06 Jun 2024 08:22:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753609 The ITAT Chennai held that a Transfer Pricing Order passed under Section 92CA(3) was barred by limitation. The TPO issued the order on 01.11.2019 for AY 2016-17, but Section 92CA(3A) requires such orders to be passed at least 60 days before the assessment limitation period expires. Since the assessment had to be completed by 31.12.2019, the TPO order should have been passed by 31.10.2019 or earlier. Following the Madras HC decision in Pfizer Healthcare, the tribunal ruled the TP proceedings were time-barred, making the assessee ineligible under Section 144C(15)(b), and consequently the assessment should have been completed within 33 months under Section 153(1). The appeal was allowed on legal grounds. Case-Laws Income Tax Mon, 03 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753609