Time limit for TP Order u/s 92CA(3A) - Order passed beyond limitation period - Transfer pricing adjustment non-est.

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....The Appellate Tribunal considered the issue of time limit for issuance of Transfer Pricing (TP) Order u/s 92CA(3A). Referring to a case law, it was held that the TP order passed on 01.11.2019 was barred by limitation. The TP adjustment became non-est due to the time limitation, making the assessee ineligible u/s 144C(15)(b). Consequently, Section 144C machinery provisions did not apply. The assessment should have been completed within 33 months from the end of the assessment year. Any order passed beyond the statutory time limit was deemed invalid. As a result, corporate additions in the assessment order were not sustainable, leading to the appeal being allowed on legal grounds.....