Tribunal, by order dated 03.04.2017, remitted certain issues to TPO for fresh consideration. TPO passed order dated 24.10.2019 making transfer pricing adjustments and consequential demand was reflected. Assessee filed objections to demand so reflected and, in absence of an order giving effect to Tribunal’s decision, sought refund of taxes paid. Alleging inaction on the part of authorities, assessee approached the High Court by filing a writ petition seeking a direction to refund an amount. A single judge held that further proceedings were not permissible and directed the revenue to consider refund. Court held that prior to the amendment to section 153 by the Finance Act, 2016, no period of limitation was prescribed for passing an order giving effect to an order of remand made by the Tribunal. However, by virtue of the amendment introduced by the Finance Act, 2016, specific time limits have been prescribed. In one contingency, limitation was three months from the end of the month in which the order of the Tribunal was received, and in another, it was nine months. If amended provisions were held applicable, time prescribed for giving effect to the order of the Tribunal dated 03.04.2017 was no longer available as on date. Even assuming that, prior to amendment, no period of limitation was prescribed, any order now sought to be passed pursuant to directions of Tribunal dated 03.04.2017 would be unreasonably delayed and barred by limitation. Accordingly, refund of taxes with applicable interest as directed could not be faulted. (AY. 2003-04)