Transfer pricing reference delay renders TPO determination without jurisdiction where reference missed statutory limitation period

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....Validity of a reference to the Transfer Pricing Officer was assessed on limitation grounds: the proviso extending assessment time for notices issued on or after 01.04.2019 gave a twelvemonth period, so a notice served 24.02.2020 required completion by 31.03.2021; tolling under pandemic ordinances extended that to 30.06.2021. Approval for reference was recorded on 10.02.2021, but the actual reference reached the TPO only in January 2022. The court concluded the TPO's determination and consequent draft assessment were made without jurisdiction because the reference was not made within the statutory limitation period, rendering the TPO order invalid.....