Validity of Transfer Pricing Notice u/s 92CA(2)

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Shubham S.Totla (Querist)
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09 April 2025 We received Notice u/s. 92CA(2) of the Income Tax Act, 1961 – Computation of Arm's Length Price-
Assessment Year 2023-24 on 07/04/2025.

My question is, wheather this notice is considered as time barred notice or not. Because it is issued after compltion of 2 years from the end of relevent financial year i.e FY 2022-23

I think Due date for issuance of this notice is 31/03/2025. Am I correct ?

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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09 April 2025 Yes, date of issuance also matters..

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Shubham S.Totla

Shubham S.Totla (Querist)
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09 April 2025 Thank You sir for your response,
Can I consider this notice as time barred and respond accordingly ?

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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09 April 2025 No.
In CIT vs. Dey Brothers, the court indeed highlighted an important aspect of legal proceedings regarding the service of notice. One key point that the court stressed was that the issue date of the notice is crucial for determining the timeline within which legal actions must be taken.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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29 September 2025 Good luck..

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