https://www.taxtmi.com/caselaws?id=785367 Final assessment orders issued after the outer limitation period in Section 153 remain subject to that provision even where the DRP procedure under Section 144C applies. Sections 144C and 153 operate cumulatively: the non-obstante clause in Section 144C(13) does not displace the statutory outer time limit for completing assessment. Applying the binding High Court ratio and consistent coordinate Tribunal rulings, the final order was treated as time-barred because it was issued after the applicable limitation deadline. The parties' rights on other issues may be revived if a pending Larger Bench decision of the Supreme Court requires modification. en-us Mon, 19 Jan 2026 00:00:00 +0530 Thu, 22 Jan 2026 08:41:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785367 Final assessment orders issued after the outer limitation period in Section 153 remain subject to that provision even where the DRP procedure under Section 144C applies. Sections 144C and 153 operate cumulatively: the non-obstante clause in Section 144C(13) does not displace the statutory outer time limit for completing assessment. Applying the binding High Court ratio and consistent coordinate Tribunal rulings, the final order was treated as time-barred because it was issued after the applicable limitation deadline. The parties' rights on other issues may be revived if a pending Larger Bench decision of the Supreme Court requires modification. Case-Laws Income Tax Mon, 19 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785367