TPO order passed after time limit prescribed u/s 92CA is barred by limitation

Frost & Sullivan (India) Private Limited Vs DCIT (ITAT Mumbai) ITAT Mumbai held that as per section 92CA of the Income Tax Act, TPO can pass the order at any time before 60 days prior to the date on which period of limitation referred u/s 153 expires. TPO order passed after the prescribed time limit is non-est and barred by limitation. Facts- Assessee, vide the present appeal, has challenged the transfer pricing adjustment of Rs. 2,18,55,896/-. Assessee mainly challenges that time limit for passing the assessment order u/s.153 is barred by limitation on the ground that ld. TPO’s order it...