Appellate Tribunal order dated 3-11 -2016  set aside the assessment order and remanded the proceeding to the AO for a fresh decision.  The PCIT had received the copy of order on 29 -12 -2016 .The time limit for completion of assessment  in terms of section 153(3) would be nine months from end of the financial year in which the order was received under section 254 of the Act . The order required to be passed on 31 -12 -2017 as the financial year ending would have been 31 -3 -2017 . The TPO issued notice dated 9-7 -2021. The assessee filed writ petition and challenged the notice stating that it was barred by limitation  and sought the refund of the amount with applicable interest u/s 244 of the Act  .  The Court held that the notice is clearly barred by limitation and directed the Department  to refund the amount in excess of admitted liability along with interest  .   ( WP No. 13646 / 2021   dt . 2-2 -2022 )( AY. 2006 -07 )