Allowing the petition the Court held that ; of the seven issues, the assessment in respect of five was set aside and the issues remanded for a fresh determination. Whether the remand was to the Transfer Pricing Officer or the Dispute Resolution Panel would not make a difference as long as what resulted from the remand was a fresh assessment of the issue. Clearly, therefore, the time-limit for completing that exercise was governed by section 153(2A) . The assessment proceedings had to necessarily be completed by the Assessing Officer within the time-limit specified in section 153(2A) of the Act. Inasmuch as the Assessing Officer failed to do so, the notice dated September 14, 2015 issued by the Assessing Officer and all proceedings consequential thereto including the order dated December 2, 2015 passed by the Assessing Officer were not valid. ( AY.2007 -08)