The writ petition was disposed of by the court by order dated March 7, 2012 remitting the matter to the Assessing Officer and directing the assessee to appear before the Assessing Officer on March 21, 2012. The Transfer Pricing Officer by an order dated June 13, 2012 after affording an opportunity to the assessee passed a draft order of assessment on July 5, 2012 and forwarded it to the assessee on July 11, 2012. The assessee filed objections before the Dispute Resolution Panel which passed an order on April 22, 2013. The Assessing Officer passed a final order on May 31, 2013. The assessee preferred an appeal before the Tribunal which held that draft assessment was completed by the Assessing Officer on July 5, 2012, beyond the period of limitation.  Tribunal held that the order was beyond period of limitation. On appeal the Court held that the Tribunal was right in holding that the draft assessment was completed by the Assessing Officer on July 5, 2012, which was beyond the period of limitation. The proceedings were stayed for a period from December,8, 2011 to March 7, 2012.i.e. for a period of 103 days and if the period of 103 days is added and a period of 60 days as prescribed in the proviso to section 153(4) is added, the draft order ought to have been passed by the Assessing Officer up to May 6, 2012, whereas the draft order has been passed on July 5, 2012 which is barred by limitation. The Court held that the order dated March 7, 2012 passed by the court neither contained any finding nor any direction.  Followed ITO v. Murlidhar Bhagwandas (1964) 52 ITR 335 (SC), Rajinder Nath v. CIT (1979) 120 ITR 14 (SC), CIT v. Chandra Bhan Bansal (2014) 46 taxmann.com 108 (All.)(HC). (AY.2008-09)