The assessee, a non-resident individual who had not filed a return, had reassessment proceedings initiated under section 147 on the ground that he had purchased immovable property for Rs. 2.55 crores in cash, and AO completed the assessment under section 144 treating the consideration as unexplained investment under section 69, which was upheld by DRP. On appeal, the Tribunal admitted the additional legal grounds challenging the validity of the reassessment and held that since the notice under section 148 was issued on February 24, 2021, and there was no reference to the TPO for determination of arm’s length price, the time-limit for completion of assessment under section 153(2) expired on March 31, 2022; however, the final assessment order under section 144 read with section 144C was passed only on January 30, 2023, beyond the prescribed time-limit, and the assessment order was accordingly quashed as barred by limitation. (AY 2017-18)