https://www.taxtmi.com/caselaws?id=424007 HC held the assessment proceedings vitiated by inordinate delay on remand and barred by limitation. The court ruled that DRP proceedings form part of assessment and must issue directions within nine months under s.144C(12); the AO must thereafter complete final orders within the statutory timelines (including the outer 33-month limit where TPO reference exists) and s.153 time limits apply on remand. Sections 144C and 153 are mutually inclusive; the non-obstante clause in s.144C(13) does not wholly exclude s.153. Orders issued beyond prescribed periods (or an unreasonable delay exceeding three years where no period is specified) are invalid. en-us Thu, 09 Jun 2022 00:00:00 +0530 Mon, 13 Oct 2025 18:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=424007 HC held the assessment proceedings vitiated by inordinate delay on remand and barred by limitation. The court ruled that DRP proceedings form part of assessment and must issue directions within nine months under s.144C(12); the AO must thereafter complete final orders within the statutory timelines (including the outer 33-month limit where TPO reference exists) and s.153 time limits apply on remand. Sections 144C and 153 are mutually inclusive; the non-obstante clause in s.144C(13) does not wholly exclude s.153. Orders issued beyond prescribed periods (or an unreasonable delay exceeding three years where no period is specified) are invalid. Case-Laws Income Tax Thu, 09 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=424007