Limitation under Section 153 governs final orders under Section 144C(13); late final assessments can be quashed as time barred.

Whether the limitation for passing a final assessment order under section 144C(13) is governed by the outer time-limit in section 153 was examined; the Tribunal accepted the view that section 144C's inbuilt timelines do not oust the outer limitation under section 153, treating the provisions as mutually inclusive. Applying that framework to the undisputed date-sheets, the Tribunal found each final assessment order was passed after the outer limitation date and therefore time-barred, resulting in quashing of those final orders in favour of the assessees.

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Issues: (i) Whether the period of limitation for passing the final assessment order under section 144C(13) of the Income-tax Act, 1961 must be determined with reference to section 153 of the Income-tax Act, 1961 (i.e., whether sections 144C and 153 are mutually inclusive) and whether the final assessment orders in the five appeals are barred by limitation.

Analysis: The Tribunal considered the competing views: the assessees relied on the Madras High Court decision in Roca Bathroom Products holding that sections 144C and 153 are mutually inclusive and that the limitation under section 153 applies to final orders under section 144C(13); the Revenue relied on the proposition that section 144C is a self-contained code with non-obstante language excluding other provisions, and also urged judicial restraint because the Supreme Court has referred the issue to a larger Bench and passed interim directions affecting citation of certain High Court reasoning. The Tribunal examined the reasoning in Roca Bathroom Products and subsequent appellate and coordinate-bench orders which interpret the timelines under sections 144C and 153 as inter-dependent, noting that section 144C contains inbuilt timelines but does not oust the outer limit prescribed by section 153. The Tribunal then applied the legal framework to the undisputed date-sheets for the five assessment years and found that in each case the final assessment order was passed after the outer limitation date computed with reference to section 153; accordingly those final orders were time-barred.

Conclusion: The final assessment orders for all five appeals are barred by limitation and are quashed; the appeals are therefore allowed in favour of the assessees.

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