https://www.taxtmi.com/caselaws?id=785878 The limitation period for passing a final assessment under section 144C(13) must be determined with reference to section 144C read with section 153, because the two provisions are interdependent and govern assessment timelines for transfer pricing matters; applying that ratio, the final assessment order for the year under challenge was held to be barred by limitation and was quashed. The Tribunal followed earlier decisions establishing mutual inclusivity of sections 144C and 153 and, noting the Supreme Court reference on this issue, granted liberty to revive the appeal on merits if the larger bench decision necessitates modification. en-us Thu, 29 Jan 2026 00:00:00 +0530 Mon, 02 Feb 2026 08:20:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785878 The limitation period for passing a final assessment under section 144C(13) must be determined with reference to section 144C read with section 153, because the two provisions are interdependent and govern assessment timelines for transfer pricing matters; applying that ratio, the final assessment order for the year under challenge was held to be barred by limitation and was quashed. The Tribunal followed earlier decisions establishing mutual inclusivity of sections 144C and 153 and, noting the Supreme Court reference on this issue, granted liberty to revive the appeal on merits if the larger bench decision necessitates modification. Case-Laws Income Tax Thu, 29 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785878