https://www.taxtmi.com/caselaws?id=783738 The dominant issue was whether the final assessment order passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B was barred by limitation. Relying on HC rulings holding that the "upper time limit" in s.153(1) and the extended period in s.153(4) (where a reference u/s 92CA is made) govern even draft/final order regimes under s.144C and faceless procedures under s.144B, the Tribunal held that any final order beyond that outer limit is void. As the outer limitation expired on 30.09.2021, the final order dated 28.07.2022 was time-barred and was quashed; the appeal was allowed. en-us Wed, 10 Dec 2025 00:00:00 +0530 Mon, 22 Dec 2025 07:49:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783738 The dominant issue was whether the final assessment order passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B was barred by limitation. Relying on HC rulings holding that the "upper time limit" in s.153(1) and the extended period in s.153(4) (where a reference u/s 92CA is made) govern even draft/final order regimes under s.144C and faceless procedures under s.144B, the Tribunal held that any final order beyond that outer limit is void. As the outer limitation expired on 30.09.2021, the final order dated 28.07.2022 was time-barred and was quashed; the appeal was allowed. Case-Laws Income Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783738