TPO order passed beyond time limit prescribed u/s 92CA(3) is barred by limitation

Shell India Markets Pvt. Ltd. Vs ACIT (ITAT Mumbai) ITAT Mumbai held that as per section 92CA(3) TPO order should be passed before 60 days prior to the date prescribed u/s 153 of the Act. Accordingly, in present case, TPO order passed on 30/01/2015 instead of 29/01/2015 is non-est and liable to be quashed as being barred by limitation. Facts- The assessee company is engaged in business of marketing motor spirit (petrol) and high-speed diesel through retail outlets, providing shared services to its group companies worldwide. Trading and Manufacturing and selling of Modified Bitumen. Emulsion (B...