Following directions of the Tribunal, the Transfer Pricing Officer passed an order under section 92CA on 30 January 2021. The Assessing Officer failed to frame the final assessment within the time prescribed under section 153(3). The AO’s claim that the TPO’s order was not communicated or known to him was factually untenable. The limitation period under section 153(3) runs from the date the AO receives the Tribunal/TPO order; even allowing benefits of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the assessment should have been completed by 30 September 2021. The assessment passed on 13 February 2023 was therefore barred by limitation and was quashed. Additionally, the AO’s adjustments of refunds in 2022 against a non-existent demand for AY 2011-12 were improper.(AY. 2011-12)