The Tribunal admitted additional ground on question of law. Allowing the appeal the Tribunal held that TPO had passed the order under section 92CA on the 60th day of the limitation period prescribed in sub-sections 153(1), 153(4) on November 1, 2019. Time limit for passing the order expired on October 31, 2019. The Assessee did not qualify as an eligible assessee under section 144C(15)(b)(i) of the Act. The Assessing Officer could not have assumed jurisdiction to invoke section. 144C for passing the draft assessment order. The time limit expired  on December 31, 2019, even if the benefit of the extended period of 12 months was granted on account of making a valid reference under section 92CA. The final assessment order  was passed on October 31, 2021  therefore the order is barred by limitation. The transfer pricing order of November 1, 2019 and the final assessment order of March 31, 2021, were to be quashed as being bad in law. (AY. 2016-17