https://www.taxtmi.com/caselaws?id=787805 A Tribunal remand directing a fresh order by the Transfer Pricing Officer under the transfer pricing provisions is governed by the statutory fresh order limitation (Section 153(3)) and not by the extended time for in course references; the distinction between a reference made by an Assessing Officer during assessment and a Tribunal directed fresh order is determinative. Computation runs from the end of the financial year in which the Tribunal's order is received; on the facts the limitation expired at the end of the relevant FY and subsequent revenue action is time barred, entitling the assessee to refund with interest. en-us Sat, 21 Feb 2026 00:00:00 +0530 Thu, 12 Mar 2026 08:33:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787805 A Tribunal remand directing a fresh order by the Transfer Pricing Officer under the transfer pricing provisions is governed by the statutory fresh order limitation (Section 153(3)) and not by the extended time for in course references; the distinction between a reference made by an Assessing Officer during assessment and a Tribunal directed fresh order is determinative. Computation runs from the end of the financial year in which the Tribunal's order is received; on the facts the limitation expired at the end of the relevant FY and subsequent revenue action is time barred, entitling the assessee to refund with interest. Case-Laws Income Tax Sat, 21 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787805