https://www.taxtmi.com/caselaws?id=786010 Limitation for passing the final assessment order under the transfer pricing regime must be determined by reading the limitation provisions of the specific transfer pricing procedure together with the general limitation provision, treating the two as mutually inclusive and overlapping; therefore the final assessment order for the relevant year was found timebarred and quashed. The tribunal followed prior high court and tribunal precedents applying the mutual inclusion principle, and granted liberty to revive the appeal on other merits if the pending Supreme Court larger bench decision alters this limitation analysis. en-us Fri, 23 Jan 2026 00:00:00 +0530 Wed, 04 Feb 2026 08:24:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786010 Limitation for passing the final assessment order under the transfer pricing regime must be determined by reading the limitation provisions of the specific transfer pricing procedure together with the general limitation provision, treating the two as mutually inclusive and overlapping; therefore the final assessment order for the relevant year was found timebarred and quashed. The tribunal followed prior high court and tribunal precedents applying the mutual inclusion principle, and granted liberty to revive the appeal on other merits if the pending Supreme Court larger bench decision alters this limitation analysis. Case-Laws Income Tax Fri, 23 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786010