Section 144C of the Act is a self-contained code of assessment and time limits are inbuilt each stage of the procedure contemplated. However this does not lead to the conclusion that overall time limits have been eschewed in the process. The Statute having set time limits at every step, there is no reason to take a stand that proceedings on remand to the DRP may be done at leisure sans the imposition of any time limit at all. The non-obstante clause in Section 144C would not exclude the operation of Section 153 as a whole since it implies that irrespective of availability of larger time to conclude the proceedings, final orders are to be passed within time limit prescribed in Section 153 of the Act. SLP is granted to the Revenue. (AY.2009-10, 2010-11)
CIT. v. Roca Bathroom Products P. Ltd (2023) 291 Taxman 529 (SC) Editorial : Refer CIT. v. Roca Bathroom Products P. Ltd (2022) 445 ITR 537 / 216 DTR 323 / 328 CTR 14 (Mad.)(HC) Dy. CIT v. Freight Systems (India) P. Ltd. (2022) 445 ITR 537/ 216 DTR 323 / 328 CTR 14 (Mad.)(HC) Decisions of single judge affirmed, CIT. v. Roca Bathroom Products P. Ltd (2021) 432 ITR 192 (Mad)(HC)/ Dy. CIT v. Freight Systems (India) P. Ltd. (2021) 18 ITR-OL 468 (Mad)(HC)
S. 144C : Reference to dispute resolution panel-Limitation-Notice by Dispute Resolution Panel four years after direction by Tribunal-Barred by limitation-High Court has power to quash show-cause notice-Decisions of single judge affirmed-SLP is granted to the Revenue. [S. 92C, 92CA, 144C(13), 153, 254(1), Art. 136]