https://www.taxtmi.com/caselaws?id=783668 The dominant issue was whether the final assessment order was time-barred under s. 153(1) r/w s. 153(4) of the Income-tax Act despite the DRP mechanism in s. 144C. Relying on HC authority holding that ss. 144C and 153 are mutually inclusive, the ITAT held that s. 153 prescribes the outer limitation for completing the assessment, while s. 144C(13) only restricts the time within which the AO must pass the final order after DRP directions and does not extend the statutory limitation. Consequently, the final assessment order dated 18.10.2024 was held barred by limitation and was quashed. en-us Wed, 19 Nov 2025 00:00:00 +0530 Thu, 18 Dec 2025 15:28:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783668 The dominant issue was whether the final assessment order was time-barred under s. 153(1) r/w s. 153(4) of the Income-tax Act despite the DRP mechanism in s. 144C. Relying on HC authority holding that ss. 144C and 153 are mutually inclusive, the ITAT held that s. 153 prescribes the outer limitation for completing the assessment, while s. 144C(13) only restricts the time within which the AO must pass the final order after DRP directions and does not extend the statutory limitation. Consequently, the final assessment order dated 18.10.2024 was held barred by limitation and was quashed. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783668