Held that it was an undisputed fact that for the assessment year 2016-17, the Transfer Pricing Officer had passed the order under section 92CA on the 60th day of the limitation period prescribed in sub-sections (1) and (4) of section 153; any order not passed prior to that date would be barred by the limitation. As a result, the final assessment order passed by the Assessing Officer was clearly bad being beyond the period of limitation. As the assessee had taken its legal ground for the first time before the Tribunal and the Dispute Resolution Panel had not had an occasion to examine the assessee’s case, the issue was to be set aside to the Assessing Officer to decide the assessee’s preliminary objections on the matter of limitations in the light of this decision. The Assessing Officer was directed to obtain necessary directions from the Dispute Resolution Panel to adjudicate the additional grounds taken up by the assessee.(AY.2012-13, 2016-17)