DRP assessment quashed as time-barred – Section 153 overrides Section 144C timelines

Centre For General Education Society Vs CIT Exemption (ITAT Delhi) The Delhi ITAT quashed the final assessment order passed u/s 143(3) r.w.s. 144C(13) for AY 2020-21 as barred by limitation, holding that the outer time limit prescribed under section 153 continues to govern even DRP cases. The Tribunal rejected the Revenue’s plea to defer adjudication merely because the issue of interplay between sections 144C and 153 is pending before the Supreme Court. It held that, in the absence of any stay, the Madras High Court judgment in Roca Bathroom Products (P) Ltd. remains binding and must be foll...