The assessee, a non-resident, was subjected to reassessment under section 147 on the basis of alleged unexplained investment. A draft assessment order was issued under section 144C and, after the DRP proceedings, the final assessment order was passed beyond one year from the end of the financial year in which notice under section 148 was served. The Revenue contended that the extended limitation applicable to eligible assessees governed by section 144C applied. The Tribunal held that the additional period under section 153(4) is available only where a reference has been made to the Transfer Pricing Officer under section 92CA. Since no such reference was made, the normal limitation under section 153(2) applied and the reassessment order was barred by limitation and liable to be quashed. (AY. 2017-18)