ORDER :

The present writ petition has been filed against the impugned order dated 24.09.2010 passed by the 1st respondent/Dispute Resolution Panel for the assessment year 2006-2007 under Section 144C (5) read with Section 144C (8) of the Income Tax Act, 1961.

2. The relevant portion of the impugned order dealing with limitation reads as under:-

“2.3. Before us the assessing officer has presented the case records, the assessment folder and made written submission on this issue vide letter dated 25/08/2010. Briefly, the A.O's submission is that the A.O during the course of assessment proceedings found that the value of International transactions in this case for the relevant assessment year exceeded Rs.15 crore, he therefore, vide a letter dated 11/11/2008 addressed to the CIT u/s. 92 CA requested the CIT for approval as required before making a reference to the TPO. The CIT after considering the subject mater accorded his approval vide letter dated 18/11/2008 to the A.O., therefore, the process for Transfer Pricing Audit u/s. 92CA had commenced. The A.O therefore, submitted that the communication dated 17/02/2009 by the A.O to the TPO is merely a formality and is not a fatal defect in