Order passed beyond limitation period by TPO u/s 92CA(3A) is unsustainable

Mondelez India Foods Private Limited Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that any order passed by the TPO beyond a period of limitation as prescribed under the provisions of section 92CA(3A) of the Income Tax Act is bad in law.

Facts-

Assessee has submitted that as per section 92CA(3A) of the Act, where reference is made to the TPO, the TPO is required to pass order under section 92CA(3) of the Act at any time before sixty days prior to the date on which the peri

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