The Supreme Court noted divergence of opinion on whether the time taken in proceedings before the Dispute Resolution Panel under s. 144C is to be subsumed within or excluded from the limitation period prescribed under s. 153 for completion of assessment. While examining the scheme of ss. 144C and 153, the Court observed that s. 144C prescribes a special procedure with fixed timelines for eligible assessees, whereas s. 153 governs overall limitation for completion of assessments. Since conflicting interpretations existed regarding whether, even where s. 144C applies, the twelve-month limitation contemplated under s. 153(3) would continue to govern completion of assessment and what constitutes the outer time limit for passing the final assessment order pursuant to DRP directions, the Court directed that the matter be placed before the Hon’ble Chief Justice of India for constitution of an appropriate Larger Bench to authoritatively settle the issue. (AY. 2014-15, 2018-19)