The Supreme Court delivered a split verdict on the time limit for completing assessments under Section 144C of the Income Tax Act.
Justice BV Nagarathna held that the 12-month limit under Section 153(3) applies even when the Dispute Resolution Panel (DRP) is involved, making delayed assessments invalid.
However, Justice Sanjay Karol disagreed, stating that Section 144C has its own independent timeline, and applying Section 153 would disrupt assessments in complex cases.
Due to the disagreement, the matter is now referred to a larger bench for a final decision.
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