https://www.taxtmi.com/highlights?id=104657 Assessment limitation following remand of a transfer-pricing issue is governed by section 153(3) where the remand is to the Assessing Officer under Rule 28 and requires verification and a hearing. A fresh reference to the Transfer Pricing Officer, absent fresh satisfaction under section 92CA(1), does not attract section 153(4) or extend the completion period; the consequential assessment was therefore quashed as time-barred. Although quoting a DIN in Dispute Resolution Panel directions is mandatory, omission from the directions did not invalidate them where a separate authenticated intimation identified the directions and carried the DIN. The DIN objection was rejected. en-us Thu, 08 Oct 2026 08:45:20 +0530 Thu, 08 Oct 2026 08:45:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104657 Assessment limitation following remand of a transfer-pricing issue is governed by section 153(3) where the remand is to the Assessing Officer under Rule 28 and requires verification and a hearing. A fresh reference to the Transfer Pricing Officer, absent fresh satisfaction under section 92CA(1), does not attract section 153(4) or extend the completion period; the consequential assessment was therefore quashed as time-barred. Although quoting a DIN in Dispute Resolution Panel directions is mandatory, omission from the directions did not invalidate them where a separate authenticated intimation identified the directions and carried the DIN. The DIN objection was rejected. Highlights Income Tax Thu, 08 Oct 2026 08:45:20 +0530 https://www.taxtmi.com/highlights?id=104657