Sec. 92C of Income Tax Act, 1961—Transfer Pricing— The mere issuance of draft assessment order, when it was legally not required to be issued, cannot end up enhancing the time limit for completing the assessment under section 143(3), therefore, the plea of the assessee was upheld, thus, the impugned assessment order is indeed time barred. - IPF INDIA PROPERTY CYPRUS (NO.1) LTD. V/s DY. CIT - [2020] 183 ITD 046 (ITAT-MUMBAI)