Supreme Court of India

Assistant Commissioner of Income Tax (international Taxation) & Others v. Shelf Drilling Ron Tappmeyer Ltd. Etc.

Neutral citation
Reported as [2025] 8 S.C.R. 1574
Bench B.V. Nagarathna and Satish Chandra Sharma JJ.
Decided 8 August 2025

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

What the Court ordered

Summary of Conclusions: 15.3 The summary of the aforesaid discussion can be made as under: (i) Section 143 of the Act states that when a return has been filed under Section 139 or in response to a notice of sub- section (1) of Section 142, and the same is processed, it would lead to an assessment order being passed by the Assessing Officer.

Judgment, page 118

From the headnote

Issue for Consideration The present matter raised important questions of law relating to interpretation and interplay between Section 144C and Section 153(3) of the Income Tax Act, 1961. The question for consideration was on the applicability of Section 153 to a proceeding under Section 144C namely, whether the period of eleven months as envisaged under Section 144C should be over and above the limitation period prescribed, particularly, under Section 153(1) or (3), as the case may be. In other words, whether the time consumed for concluding the proceeding under Section 144C has to be

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