Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barred.

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....Assessment limitation following remand of a transfer-pricing issue is governed by section 153(3) where the remand is to the Assessing Officer under Rule 28 and requires verification and a hearing. A fresh reference to the Transfer Pricing Officer, absent fresh satisfaction under section 92CA(1), does not attract section 153(4) or extend the completion period; the consequential assessment was therefore quashed as time-barred. Although quoting a DIN in Dispute Resolution Panel directions is mandatory, omission from the directions did not invalidate them where a separate authenticated intimation identified the directions and carried the DIN. The DIN objection was rejected.....