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The SC delivered a fragmented verdict on the interplay between Sections 144C and 153 of the Income Tax Act regarding time limits for assessment proceedings. The majority held that the limitation period under Section 153(3) applies to draft assessment orders under Section 144C, rendering assessments time-barred if not completed within that period, thereby upholding the High Court's quashing of final assessments and directing acceptance of the returns filed. However, a dissenting opinion emphasized that Section 144C operates independently and extends beyond the timelines prescribed in Section 153, allowing adequate opportunity for dispute resolution without violating natural justice. Consequently, the SC set aside the High Court's order, allowing the Revenue to pass appropriate orders and permitting the assessee to seek remedies thereafter. Due to divergent views, the SC directed constitution of a larger Bench to reconsider these issues comprehensively.
The SC delivered a fragmented verdict on the interplay between Sections 144C and 153 of the Income Tax Act regarding time limits for assessment proceedings. The majority held that the limitation period under Section 153(3) applies to draft assessment orders under Section 144C, rendering assessments time-barred if not completed within that period, thereby upholding the High Court's quashing of final assessments and directing acceptance of the returns filed. However, a dissenting opinion emphasized that Section 144C operates independently and extends beyond the timelines prescribed in Section 153, allowing adequate opportunity for dispute resolution without violating natural justice. Consequently, the SC set aside the High Court's order, allowing the Revenue to pass appropriate orders and permitting the assessee to seek remedies thereafter. Due to divergent views, the SC directed constitution of a larger Bench to reconsider these issues comprehensively.
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