https://www.taxtmi.com/caselaws?id=758710 ITAT Mumbai held that TPO's order u/s 92CA(3) dated 01.11.2019 was time-barred as it was passed one day after the limitation period expired on 31.10.2019. Following precedents from Madras HC in Saint Gobain India and Pfizer Healthcare cases, the tribunal ruled that TPO must pass orders 60 days before the limitation period under Section 153 expires. Since the TPO's order and draft assessment order were barred by limitation, the assessee was not eligible under Section 144C(15)(b)(i), rendering the final assessment invalid. Appeal allowed. en-us Wed, 28 Aug 2024 00:00:00 +0530 Tue, 17 Sep 2024 16:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758710 ITAT Mumbai held that TPO's order u/s 92CA(3) dated 01.11.2019 was time-barred as it was passed one day after the limitation period expired on 31.10.2019. Following precedents from Madras HC in Saint Gobain India and Pfizer Healthcare cases, the tribunal ruled that TPO must pass orders 60 days before the limitation period under Section 153 expires. Since the TPO's order and draft assessment order were barred by limitation, the assessee was not eligible under Section 144C(15)(b)(i), rendering the final assessment invalid. Appeal allowed. Case-Laws Income Tax Wed, 28 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758710