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Tribunal Rules Transfer Pricing Orders Issued Late, Affirms Mandatory Time Limits for Assessments u/s 92CA(3.
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....Time limit to pass assessment u/s. 92CA(3) - Transfer pricing adjustments - After thorough consideration of the statutory provisions and legal arguments presented by both parties, the Tribunal found merit in the assessee's contention. It observed that the TPO's order, along with the subsequent draft and final assessment orders, were passed beyond the prescribed time limit. Despite the Revenue's assertion that the time limit was discretionary, the Tribunal upheld the assessee's argument, emphasizing the mandatory nature of the prescribed time frame.....