Transfer Pricing Officer's Order Exceeds Limitation Period: Issued After Deadline u/ss 92CA(3) and 153.

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....Period of limitation for palling an order passed by the TPO u/s 92CA (3) read with section 153 - Computation of period of 60 days given by the taxpayer extracted in the preceding para no.20 cannot be faulted with on any ground because from 31.03.2013, the date of passing order of the AO, 60 days was to be computed by excluding the date of order i.e. 31.03.2013. So, while excluding the date 31.03.2013, the day of passing the order, the order was required to be passed by the TPO by 29.01.2013 whereas the impugned order has been passed on 31.01.2013 which is barred by limitation. - AT....