Sections 144C and 153 require harmonious construction when...

Sections 144C and 153 require harmonious construction when determining limitation for a final assessment made pursuant to DRP directions. The non-obstante clause in section 144C(13) does not displace the outer time limit under section 153; the final assessment must therefore be completed within that prescribed limitation period. Applying the binding High Court precedent, the ITAT treated the final assessment for Assessment Year 2018-19 as time-barred and quashed it. Merits grounds remained open, with liberty to seek revival if a Supreme Court decision requires modification.