Limitation on income-tax final assessment under Sections 144C and 153: assessments beyond statutory period are barred and quashed.

Assessment validity is governed by the limitation framework created by Sections 144C and 153; where the final assessment order is rendered after the statutory time limit prescribed by those provisions, the order is time-barred. The Article applies the established principle that the temporal limits under the reassessment procedure determine viability of the final order, and follows precedent holding that a final assessment passed beyond that period must be quashed. Consequence: final assessment orders completed after the applicable limitation period have no legal effect and are subject to being set aside.

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Issues: (i) Whether the final assessment order passed under section 143(3) read with section 144C(13) is barred by limitation and must be determined with reference to section 153 of the Income-tax Act, 1961.

Analysis: The issue requires examination of the statutory timelines prescribed by section 144C (including subsections providing timelines for draft order, DRP objections and DRP directions) alongside the limitation provisions in section 153 (including its extended timelines when TPO reference applies). The Tribunal considered the Madras High Court decision in CIT v. Roca Bathroom Products P. Ltd., and the statutory scheme showing overlapping and inter-dependent timelines for proceedings remitted to DRP or TPO. The Tribunal noted that where the final assessment order was passed after the outer time limit as determined by reading section 144C in conjunction with section 153, the order falls beyond the prescribed limitation and is liable to be set aside. The factual timeline for the assessment year showed the final order dated 30.09.2024, which was after the time-barring date computed under section 153 for the relevant assessment year.

Conclusion: The final assessment order passed under section 143(3) read with section 144C(13) is time-barred when assessed with reference to section 153 and is quashed. The appeal is allowed in favour of the assessee.

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