https://www.taxtmi.com/caselaws?id=800576 Section 144C applies where an Assessing Officer proposes a variation in returned income through a draft assessment order on or after 1 October 2009, irrespective of the assessment year. For a remand requiring fresh adjudication by the DRP rather than consequential action, the fresh-assessment limitation falls under section 153(2A). Where a fresh transfer-pricing reference is made, the fourth proviso allows two years, running from departmental receipt or knowledge of the appellate order; internal movement or delayed receipt by the particular DRP does not defer it. Section 144C(13) regulates orders following DRP directions but does not displace section 153(2A)'s limitation, rendering proceedings after expiry unsustainable. en-us Wed, 23 Sep 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800576 Section 144C applies where an Assessing Officer proposes a variation in returned income through a draft assessment order on or after 1 October 2009, irrespective of the assessment year. For a remand requiring fresh adjudication by the DRP rather than consequential action, the fresh-assessment limitation falls under section 153(2A). Where a fresh transfer-pricing reference is made, the fourth proviso allows two years, running from departmental receipt or knowledge of the appellate order; internal movement or delayed receipt by the particular DRP does not defer it. Section 144C(13) regulates orders following DRP directions but does not displace section 153(2A)'s limitation, rendering proceedings after expiry unsustainable. Case-Laws Income Tax Wed, 23 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800576