Limitation and jurisdiction rules dictate final assessment orders issued after prescribed timelines are void and quashed.

Final assessment orders issued after the timelines prescribed under the DRP procedure and the outer limitation period are time barred and lack jurisdiction; the legal analysis treats the timelines in the dispute resolution mechanism and the outer limitation as mutually inclusive, applying the outer limitation to remand and DRP stages, and therefore orders rendered beyond those combined limits are void. Factual date charts unrebutted by Revenue showed final orders were made after the applicable limitation, leading to quashing of the impugned final assessment orders and allowance of the appeals in favour of the taxpayers.

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Issues: (i) Whether final assessment orders passed after the timeline prescribed under section 144C(13) read with section 153 of the Income-tax Act, 1961 are time barred and without jurisdiction?

Analysis: The Tribunal considered the interplay between section 144C and section 153 of the Income tax Act, 1961. The analysis examined provisions of section 144C providing the DRP mechanism and its inbuilt timelines (including subsections 1, 4, 5, 12 and 13) alongside the outer time limits under section 153 (including subsections 2A, 3 and 4). The Tribunal relied on the reasoned decision of the Madras High Court in Roca Bathroom Products P. Ltd., which held that the provisions of sections 144C and 153 are mutually inclusive and that the outer limitation under section 153 applies to proceedings on remand including DRP stages; factual date charts supplied by the assessees (undisputed by the Revenue) showed final orders were passed after the applicable limitation dates computed under section 144C(13) read with section 153. The Tribunal rejected the Revenue's contention that section 144C is an entirely self contained code excluding section 153, noting that the Madras High Court and subsequent appellate treatment treat the timelines as overlapping and that orders passed beyond the prescribed limitation are without jurisdiction.

Conclusion: The final assessment orders passed after the time prescribed under section 144C(13) read with section 153 of the Income tax Act, 1961 are time barred and without jurisdiction; the impugned final assessment orders are quashed, and the appeals are allowed in favour of the assessees.

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