The HC held that assessment orders issued beyond the statutory...

The HC held that assessment orders issued beyond the statutory time limit prescribed under Section 144C(13) of the Income Tax Act are invalid and void. The court emphasized that when the legislature incorporates amendments to existing legislation, such amendments must be interpreted purposively while considering the overall statutory scheme. The court noted that amended provisions become integral parts of the statute and cannot be interpreted in isolation from other statutory provisions. Following precedents from Kerala HC in Allianz Cornhill Information Services case and Bombay HC in Vodafone Idea Limited case, the court ruled that the Assessing Officer is statutorily bound to adhere to the time limits stipulated under Section 144C(13). Any assessment order issued in breach of these mandatory time limits shall be deemed invalid. The writ petition was allowed, affirming the strict adherence to procedural timelines in tax assessment proceedings.