The Supreme Court in landmark ruling on interplay between Section 144C and Section 153 of the Income Tax Act — Majority (per Satish Chandra Sharma, J.) holds that the non-obstante clauses in Section 144C(4) and (13) exclude the application of Section 153’s limitation to the post-draft Dispute Resolution Panel (DRP) procedure, thereby confining Section 153(3)’s twelve-month period to the stage of passing the draft assessment order alone, with the statutory timelines for DRP directions and final assessment under Section 144C operating in addition and extending the overall period available to the Assessing Officer; Dissent (per Nagarathna, J.) upholds Bombay High Court’s view that the Section 144C procedure, including the DRP stage, must be fully completed within the overall limitation prescribed under Section 153, with no exclusion for time spent before the DRP, rendering delayed assessments beyond that period as time-barred., Dated- 08-08-2025