Held that assessee except in a case of reference to the TPO, extended time-limit of 12 months for completion of assessment as per S. 153(4) is not available even in a case of non-resident, even though the said assessment proceedings is covered under S. 144C of the Act. Additional ground on limitation is admitted.  On the facts the notice was issued under s. 148 on 29th March, 2021 and  served in the month of April, 2021. Though the assessment was made as per the procedure laid down in s. 144C, no reference was made under s. 92CA to the TPO.  The time-limit for completing the assessment under S. 147 was available upto 31st March, 2023 as per s. 153(2) hence  the final assessment order passed by the AO under s. 147 r/w s. 144C(13), dt. 8th Jan., 2024 is  barred by limitation.  (AY.2016-17, 2018-19)