Time limits for search-based assessments are a self-contained code; extension applies only with a transfer pricing reference, otherwise late orders are void.

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....Where assessments arise from search proceedings, the statutory time-frame for completion prescribed for search-based assessments constitutes a self-contained code and must be complied with; applying that rule the Tribunal found final orders issued after the applicable twelve month period were beyond limitation and void. The decision clarifies that the additional twelve month extension in the proviso is available only where a transfer pricing reference to the Transfer Pricing Officer is made during proceedings; absent such a reference the Assessing Officer cannot rely on the proviso to extend time and late assessments must be quashed.....