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This case deals with the applicability of Section 153, the limitation provision, to proceedings u/s 144C of the Income Tax Act. The key issues are whether the 11-month period envisaged u/s 144C should be in addition to the time limit prescribed u/s 153(1) read with Section 153(4), or whether it needs to be subsumed within the timelines stipulated u/s 153. The High Court observed that the Supreme Court is currently considering this issue arising from decisions of various High Courts, including the present case. The Revenue has issued circulars seeking adjournments in pending cases involving this issue before the Income Tax Appellate Tribunal, awaiting the Supreme Court's decision. Regarding interim relief, the High Court noted that assessees in similar cases have succeeded before the Madras and Delhi High Courts, and the Supreme Court has not stayed those orders setting aside the assessment orders. Consequently, the High Court continued the ad-interim order dated 28 June 2024 till the final disposal of this petition.
This case deals with the applicability of Section 153, the limitation provision, to proceedings u/s 144C of the Income Tax Act. The key issues are whether the 11-month period envisaged u/s 144C should be in addition to the time limit prescribed u/s 153(1) read with Section 153(4), or whether it needs to be subsumed within the timelines stipulated u/s 153. The High Court observed that the Supreme Court is currently considering this issue arising from decisions of various High Courts, including the present case. The Revenue has issued circulars seeking adjournments in pending cases involving this issue before the Income Tax Appellate Tribunal, awaiting the Supreme Court's decision. Regarding interim relief, the High Court noted that assessees in similar cases have succeeded before the Madras and Delhi High Courts, and the Supreme Court has not stayed those orders setting aside the assessment orders. Consequently, the High Court continued the ad-interim order dated 28 June 2024 till the final disposal of this petition.
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