https://www.taxtmi.com/caselaws?id=783805 Assessment limitation may be raised through additional legal grounds at the appellate stage where the necessary facts are already on record and the grounds affect tax liability. Supreme Court Covid-19 limitation extensions for judicial or quasi-judicial proceedings do not enlarge the Assessing Officer's statutory deadline to complete assessments. For eligible assessees under the draft order and DRP process, the outer time-limit remains governed by section 153, including the transfer-pricing extension where applicable; section 144C(13) requires prompt action after DRP directions but does not replace or extend that outer limit. Final assessment orders passed after the statutory deadline are barred by limitation and liable to be quashed, leaving merits open. en-us Fri, 12 Dec 2025 00:00:00 +0530 Tue, 27 Jan 2026 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783805 Assessment limitation may be raised through additional legal grounds at the appellate stage where the necessary facts are already on record and the grounds affect tax liability. Supreme Court Covid-19 limitation extensions for judicial or quasi-judicial proceedings do not enlarge the Assessing Officer's statutory deadline to complete assessments. For eligible assessees under the draft order and DRP process, the outer time-limit remains governed by section 153, including the transfer-pricing extension where applicable; section 144C(13) requires prompt action after DRP directions but does not replace or extend that outer limit. Final assessment orders passed after the statutory deadline are barred by limitation and liable to be quashed, leaving merits open. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783805