HC set-asides notice issued by TPO in remand proceedings as same was barred by limitation

INCOME TAX : Where Tribunal passed order dated 3-11-2016 setting aside order of assessment and remanded proceedings to Transfer Pricing Officer and Commissioner received copy of aforesaid order on 29-12-2016 and thereafter Transfer Pricing Officer issued on assessee a notice dated 9-7-2021, in terms of time period available under section 153 notice dated 9-7-2021 was barred by limitation

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