Diageo India P. Ltd. v. ITO (2024)112 ITR 435 (Mum)(Trib)

S. 144C : Reference to dispute resolution panel-Limitation-Transfer Pricing Officer to pass order at any time before 60 days prior to limitation-Order is barred by limitation. [S. 92CA(3A), 153]

Held, that the order of the Transfer Pricing Officer should have been passed on or before October 31, 2019 whereas the order dated November 1, 2019 was beyond the time-limit stipulated under section 92CA(3A) read with section 153 of the Act.  The order of the Transfer Pricing Officer is time-barred, order is quashed.   (AY. 2016-17