Final Orders After DRP Beyond Section 153 Limit Quashed Despite Pending Supreme Court Reference

Philip Morris Services India SARL Vs DCIT (ITAT Delhi) Final Orders After DRP Beyond Section 153 Limit Quashed Despite Pending Supreme Court Reference The assessee challenged the final assessment orders for AYs 2009-10 and 2010-11 as being time-barred, contending that even in DRP cases the outer limitation under section 153 governs the final order under section 144C(13). The Revenue argued that section 144C is a self-contained code and that, since the issue is pending before a larger Bench of the Supreme Court in the Shelf Drilling and Roca Bathroom matters, the Tribunal should defer adjudicat...