https://www.taxtmi.com/caselaws?id=472151 Outer limitation for completing assessments remains controlling where a Transfer Pricing Officer reference extends the assessment period and Dispute Resolution Panel directions require a final order. The non-obstante clause governing implementation of Panel directions fixes the final-stage period but neither overrides nor enlarges the statutory outer limit. COVID-19 limitation extensions do not apply to original assessment proceedings conducted by tax authorities. Consequently, final assessment orders issued after the applicable outer limitation period for both assessment years were barred by limitation and liable to be quashed. en-us Wed, 26 Nov 2025 00:00:00 +0530 Wed, 30 Sep 2026 19:00:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472151 Outer limitation for completing assessments remains controlling where a Transfer Pricing Officer reference extends the assessment period and Dispute Resolution Panel directions require a final order. The non-obstante clause governing implementation of Panel directions fixes the final-stage period but neither overrides nor enlarges the statutory outer limit. COVID-19 limitation extensions do not apply to original assessment proceedings conducted by tax authorities. Consequently, final assessment orders issued after the applicable outer limitation period for both assessment years were barred by limitation and liable to be quashed. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472151