For AY 2010–11, following transfer pricing adjustments and partial relief by the Dispute Resolution Panel, the Tribunal remitted the matter to the AO on 21 October 2020. Because the Tribunal’s order was passed after 1 April 2019, the nine-month period in s. 153(3) is to be read as twelve months; computing twelve months from 21 October 2020 meant the Department’s jurisdiction to make an assessment pursuant to the Tribunal’s direction ended on 21 October 2021. Thereafter, notices issued on 6 March 2023 and 19 March 2023 were time‑barred and were therefore quashed and set aside.(AY. 2010-11)