<h1>Split Verdict on Whether Section 144C Timelines Are Separate from Section 153 Limitation Periods in Tax Cases</h1> A Supreme Court bench delivered a split verdict on an income tax appeal involving foreign drilling companies concerning the interpretation of Sections 144C and 153 of the Income Tax Act, 1961. The dispute focused on whether the timeline for issuing draft assessment orders under Section 144C is independent or included within the overall limitation period under Section 153 for non-resident assessees. One judge upheld the high court's ruling that assessment proceedings were time-barred as final orders were not passed within the extended deadline. The other judge allowed the appeal, emphasizing a harmonious interpretation of both sections to avoid denying fair opportunity and breaching natural justice. Due to the conflicting opinions, the matter will be referred to the Chief Justice of India for directions to place it before a larger bench. The case arose from petitions by non-resident assessees engaged in offshore drilling, who had declared losses after opting out of a presumptive taxation scheme.