CMA Final · Direct Tax Laws and International Taxation · Transfer Pricing
A TPO's order under section 166(6) for a reference concerning an assessment whose limitation period expires on 31 March 2028 must, as per the substituted sub-section (7) effective 1 April 2026, be made on or before which date?
The TPO's order must be made on or before 31 January 2028. Under the substituted sub-section (7), where the assessment limitation expires on 31 March of a year, the TPO order is due by 31 January of that year, replacing the earlier sixty-day rule.
- A31 January 2028Correct
- B31 October 2027
- C30 January 2028
- D31 March 2028
Explanation
Sub-section (7) requires the order at any time before one month prior to the month in which limitation expires. Where the period expires on 31 March of a year, the order must be made by 31 January of that year. The old 60-day rule would give about 30 January, which is the distractor.
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