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CMA Final · Direct Tax Laws and International Taxation · Transfer Pricing

A reference was made to the TPO under section 166(1) and the time limit for the assessment order expires on 31 March of a year. Under section 166(7) as substituted w.e.f. 1-4-2026, by when must the TPO's order under section 166(6) be made?

The TPO must pass the order by 31st January of that year. Under the substituted section 166(7), the order is due before one month prior to the month of expiry of the assessment limitation, replacing the earlier sixty-day rule.

  1. A31st January of that yearCorrect
  2. B31st December of the preceding year
  3. C30th April of that year
  4. DSixty days before 31 March

Explanation

Section 166(7) now requires the order before one month prior to the month in which the limitation expires. Where it expires on 31 March, the TPO order is due on or before 31 January. The old rule of sixty days before expiry was replaced and would give a different date.

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