In this case the Tribunal had set aside only one issue i.e., transfer pricing adjustment, out of multiple issues to the AO/TPO for passing a speaking order, the AO was required to pass the assessment order within the period of limitation of S. 153(2A) of the Act. Since the limitation for completion of fresh assessment in terms of S. 153(2A) expired on 31.03.2016, the order passed on 27.07.2017 is beyond the limitation period. (AY. 2008-09)
Bechtel India (P) Ltd. v. Addl. CIT (2018) 191 TTJ 280 (Delhi)(Trib.)
S. 153 : Assessment – Limitation – AO is required to pass the assessment order within the period of limitation available under S. 153(2A) of the Act. [ S.153(2A) ]