https://www.taxtmi.com/caselaws?id=794887 The outer limitation under Section 153 continues to govern final assessments made after the DRP process under Section 144C, because the provisions must be read harmoniously and Section 144C(13) does not wholly exclude Section 153. Applying the reasoning in Roca Bathroom Products, the Tribunal treated the applicable outer limit as 30 September 2021; a final assessment order made on 29 July 2022 was therefore beyond limitation and invalid. The Tribunal also rejected deferral merely because the statutory issue was pending before the Supreme Court and an interim order existed in Shelf Drilling. Section 158AB was regarded as the Revenue's mechanism for dealing with an identical pending question, while the unstayed High Court precedent remained applicable. The assessment was annulled and the connected rectification appeal became infructuous. en-us Wed, 28 Jan 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794887 The outer limitation under Section 153 continues to govern final assessments made after the DRP process under Section 144C, because the provisions must be read harmoniously and Section 144C(13) does not wholly exclude Section 153. Applying the reasoning in Roca Bathroom Products, the Tribunal treated the applicable outer limit as 30 September 2021; a final assessment order made on 29 July 2022 was therefore beyond limitation and invalid. The Tribunal also rejected deferral merely because the statutory issue was pending before the Supreme Court and an interim order existed in Shelf Drilling. Section 158AB was regarded as the Revenue's mechanism for dealing with an identical pending question, while the unstayed High Court precedent remained applicable. The assessment was annulled and the connected rectification appeal became infructuous. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794887