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CA Final · Direct Tax Laws & International Taxation · Transfer Pricing

Kaveri Textiles Ltd's assessment for a tax year is time-barred on 31 March 2027, and the reference to the TPO was made under section 166(1). Applying section 166(7) as substituted w.e.f. 1-4-2026, by which date must the TPO pass the order under section 166(6)?

The TPO must pass the order on or before 31 January 2027. Under section 166(7), the order is due before one month prior to the month in which assessment limitation expires, and where that period expires on 31 March, the deadline is 31 January of that year.

  1. A31 January 2027Correct
  2. B31 December 2026
  3. C31 October 2026
  4. D31 March 2027

Explanation

Section 166(7) requires the order to be made before one month prior to the month in which the limitation expires. Where the period expires on 31 March of a year, the order must be made on or before 31 January of that year. The 31 December 2026 date would be the old-style approach of roughly sixty days and is not the stated rule.

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