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

Under section 166(7) as substituted w.e.f. 1-4-2026, the period of limitation for making an assessment order expires on 31 March of a year. By which date must the TPO make the order under section 166(6) where a reference was made?

The TPO must pass the order on or before 31 January of that year. Under the substituted section 166(7), the order is due before one month prior to the month in which limitation expires, so a 31 March expiry gives a 31 January deadline.

  1. A31 January of that yearCorrect
  2. B31 December of the preceding year
  3. C1 February of that year
  4. D31 March of that year

Explanation

The order may be made at any time before one month prior to the month in which limitation expires. For expiry on 31 March, section 166(7)(a) requires the order on or before 31 January. The earlier 'sixty days' rule has been replaced.

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