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Interplay between limitation for final assessment under section...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to revive appeal
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Interplay between limitation for final assessment under section 144C(13) and section 153 was considered, and the tribunal applied binding precedent to treat limitation as governed by section 153 read with section 144C; consequence: the final assessment order for the stated year was held timebarred and quashed. The tribunal followed prior High Court and ITAT decisions endorsing mutual inclusion of the two provisions and cited a pending Supreme Court reference; consequence: parties are granted liberty to revive the appeal for merits if the higher court's ultimate ruling requires modification of this order.
Interplay between limitation for final assessment under section 144C(13) and section 153 was considered, and the tribunal applied binding precedent to treat limitation as governed by section 153 read with section 144C; consequence: the final assessment order for the stated year was held timebarred and quashed. The tribunal followed prior High Court and ITAT decisions endorsing mutual inclusion of the two provisions and cited a pending Supreme Court reference; consequence: parties are granted liberty to revive the appeal for merits if the higher court's ultimate ruling requires modification of this order.
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