Court Confirms Section 144C of Income Tax Act as Procedural; Dismisses Petitioner's Objections on Timeliness and Substance.

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....Assessment completed u/s 144C against a petitioner/Non-Resident Indian - The High Court held that Section 144C is a procedural provision introduced for the benefit of assesses, including NRIs, effective from April 1, 2020. The petitioner's objection to being assessed under Section 144C was deemed meritless as the provision is beneficial and procedural, not substantive. The Court emphasized that the petitioner failed to raise this objection before the assessing authority, rendering it invalid. - Further on the issue of limitation: The High Court noted the provided timeline demonstrated compliance with statutory procedures and extensions granted under TOLA. It concluded that the assessment order was passed within the prescribed time limit, as per the provisions of Section 144C, rendering the petitioner's objection baseless.....