https://www.taxtmi.com/caselaws?id=798570 Limited appellate remands directing exclusion of comparables and fresh examination of specified comparable-company issues fall within Section 153(5) of the Income-tax Act, rather than a fresh assessment. Where verification and a hearing are required, the second proviso applies the Section 153(3) limitation period for giving effect to the appellate order. Receipt of the appellate order on 17 October 2022 required completion by 31 March 2024. The Section 153(4) extension was unavailable because remand to the Transfer Pricing Officer differed from an Assessing Officer's reference under Section 92CA(1). The delayed assessment and transfer-pricing orders were time-barred and quashed. en-us Mon, 24 Aug 2026 00:00:00 +0530 Wed, 09 Sep 2026 08:20:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798570 Limited appellate remands directing exclusion of comparables and fresh examination of specified comparable-company issues fall within Section 153(5) of the Income-tax Act, rather than a fresh assessment. Where verification and a hearing are required, the second proviso applies the Section 153(3) limitation period for giving effect to the appellate order. Receipt of the appellate order on 17 October 2022 required completion by 31 March 2024. The Section 153(4) extension was unavailable because remand to the Transfer Pricing Officer differed from an Assessing Officer's reference under Section 92CA(1). The delayed assessment and transfer-pricing orders were time-barred and quashed. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798570