Section 144C – SLP granted against HC order that section 144C and 153 are mutually inclusive and not mutually exclusive as both contain provisions relating to section 92CA and are interdependent and overlapping and hence, period of limitation prescribed under section 153(2A) or 153(3) is applicable and, when matters are remanded back irrespective of whether it is to AO or TPO or DRP, duty is on AO to pass orders within stipulated time.
Commissioner of Income-tax v. Roca Bathroom Products (P.) Ltd. – [2023] 147 taxmann.com 224 (SC).