https://www.taxtmi.com/caselaws?id=778889 ITAT DELHI-AT held the transfer-pricing order passed by the TPO under section 92CA(3) invalid as barred by limitation by one day. The assessment period under section 153(1) expired on 31 Mar 2013, so the 60-day window for a s.92CA(3A) reference lapsed on 29 Jan 2013; the TPO's order fell outside that statutory period. Applying the Act's sixty-day rule (not the circular's "two months"), the tribunal set aside the TPO order and allowed the assessee's appeal. en-us Fri, 19 Sep 2025 00:00:00 +0530 Wed, 24 Sep 2025 08:08:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778889 ITAT DELHI-AT held the transfer-pricing order passed by the TPO under section 92CA(3) invalid as barred by limitation by one day. The assessment period under section 153(1) expired on 31 Mar 2013, so the 60-day window for a s.92CA(3A) reference lapsed on 29 Jan 2013; the TPO's order fell outside that statutory period. Applying the Act's sixty-day rule (not the circular's "two months"), the tribunal set aside the TPO order and allowed the assessee's appeal. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778889