2023 (6) TMI 129

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.....6875 of 2021 And W.M.P. No.7424 of 2021 - -<br>Income Tax<br>Hon&#39;ble Mr. Justice Abdul Quddhose For the Petitioner : Mr.S.Raveekumar For the Respondents : Mr.B.Rama Kumar, Senior Standing Counsel for R1, Mr.D.Prabhu Mukunth Arunkumar, Junior Standing Counsel and Mr.S.Rajesh, Junior Standing Counsel for R2 ORDER The petitioner has challenged the impugned order dated 01.11.2019, pas....

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.... Officer; 2. The Department contends that since the Transfer Pricing Officer namely, the second respondent herein has passed the order on 01.11.2019, the said order is within the period of limitation prescribed under Section 92 CA(3A) of the Income Tax Act. However, the same is disputed by the petitioner, who would contend that sixty days period expired on 31.10.2019 and therefore, the impugned....

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....the order was on 31.10.2019 and since the order was passed on 01.11.2019, the said order is barred by limitation. 4. Learned Standing Counsels appearing for the respondents would not dispute the judgment dated 31.03.2022, passed in the aforementioned Writ Appeals by the Division Bench of this Court, involving a similar issue. They would however submit that as against the Division Bench judgment....