Assessing Officer passed a draft assessment order proposing transfer pricing adjustment towards alleged international transactions alleging excessive advertisement/marketing promotion (AMP) expenditure. DRP endorsed AMP spends to be bracketed in league of international transaction and issued certain directions to Assessing Officer. Order is passed on 30-6-2022. On appeal the Tribunal held that  since FAO being designated as assessment unit (even if considered distinct from NFAC) was privy to DRP order in April 2022, limitation in extreme case scenario would run from April 2022 and will end on 31-5-2022 and, thus, assessment order having been passed on 30-6-2022, was c time barred and outside limitation period assigned under section 144C(13).  Transfer of case records by Faceless Assessing Officer (FAO) to Jurisdictional Assessing Officer (JAO) will not entitle Department to get extension of limitation period for framing assessment.  (AY. 2018-19)