Supreme Court Divided Over Tax Assessment Timelines

In a split verdict dated 8 August 2025, the top Court considered whether the Dispute Resolution Panel (DRP) timelines are excluded from tax assessment deadlines. In the majority opinion of a bench of Justices B.V. Nagarathna and Satish Chandra Sharma, stated that the DRP’s 9-month period and AO’s 1-month period under Section 144C are additional to Section 153(3) under the Income Tax Act, 1961. The Supreme Court delivered the divided decision on tax assessment deadlines for foreign companies.

The matter in Assistant Commissioner Of Income Tax vs Shelf Drilling Ron Tappmeyer Limited arose from a high court ruling making proceedings time-barred under Section 153(3), as the limitation period expired before the Draft Assessment Order (DAO) was passed.Justice Nagarathna’s view prioritised the mandatory adherence to statutory deadlines as intended by the statute, whereas Justice Sharma’s opinion allowed for the extension of timeline in complex assessments involving foreign companies and tax disputes.

The verdict found the non-obstante clauses in Section 144C timelines operate independently and override that of Section 153(3). Also, the DRP’s 9-month period and AO’s 1-month period under Section 144C are additional to Section 153(3). The judgement referred to Commissioner of Income Tax v. Hindustan Bulk Carriers and reiterated that construction of a statute should not reduce it to futility. The ratio in Franklin Templeton Trustee Services Private Limited & Anr. v. Amruta Garg & Ors. was cited to show that interpretation of laws should not set a standard which is palpably unjust, unfair, unreasonable or does not make any sense

Justice Sharma opined that should proceedings under Section 92C be invoked, the time period in view of Section 153(4) of the Income Tax Act would be extended by a period of 12 months. Section 144C of the Income Tax Act mandates adherence to fixed timelines. A final assessment order needs to be passed within one month of the Draft Assessment Order under sub-section (4), or within 11 months if objections are filed before the Dispute Resolution Panel.

Considering the divergence in opinion expressed and split verdict, the Bench directed the Registry to place the matters before the Hon’ble Chief Justice of India for constituting an appropriate Bench to consider the issues afresh.

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Hiring Now: Legal Interns at Vistaar Finance Bangalore | Paid Corporate Law Internship

Hiring Now: Legal Interns at Vistaar Finance (Bangalore)

If you are a law student looking to gain practical corporate law experience, Vistaar Finance is offering an excellent legal internship opportunity in Bangalore. This is a paid internship designed for law students who are passionate about financial legal work, compliance, and contract management. With a duration of 2–3 months, interns will have the opportunity to work closely with the in-house legal team of one of India’s leading small business finance companies.

About the Organization

Vistaar Finance is a trusted name in the financial services sector, particularly known for providing easy and affordable loans to MSMEs and SMEs. With a vision to empower small businesses across India, Vistaar Finance has built a strong presence by offering financial solutions that are simple, transparent, and effective. The company’s core values revolve around customer trust, efficiency, and compliance with all regulatory norms.

The legal department of Vistaar Finance plays a crucial role in ensuring that all financial operations, loan agreements, and company processes comply with legal and regulatory frameworks. This internship provides students with exposure to the intersection of law, finance, and compliance, offering them practical skills that go beyond textbooks.

Internship Position and Duration

  • Position: Legal Intern
  • Mode: In-office (BTM 2nd Stage, Bangalore)
  • Duration: 2–3 months
  • Type: Paid Internship

This opportunity is best suited for students who wish to gain hands-on experience in corporate law, financial regulations, and compliance.

Eligibility Criteria

Vistaar Finance is looking for highly motivated law students who are eager to explore legal issues related to finance, lending, and corporate law.

  • Must be currently pursuing a law degree (LL.B.)
  • Strong interest in corporate, financial, and business laws
  • Keen to work with an in-house legal team
  • Good research and documentation skills
  • Strong communication and organizational skills
  • Ability to work responsibly in a professional environment

Preference will be given to students who are detail-oriented, adaptable, and willing to learn from real-life legal challenges faced by a financial institution.

Key Responsibilities of Interns

Interns selected for this position will work closely with the in-house legal team and gain practical legal skills. The responsibilities include:

  • Conducting legal research on matters related to corporate and financial laws
  • Assisting in drafting and reviewing contracts, agreements, and loan documents
  • Helping the team ensure regulatory compliance with company policies and financial laws
  • Supporting documentation for loan disbursements, security agreements, and customer contracts
  • Collaborating with different departments to ensure smooth legal operations
  • Assisting in preparing legal briefs, notices, and other documents as required

This internship ensures that interns gain exposure to corporate governance, contract law, and compliance issues within a financial services company.

Skills You Will Gain

Students interning at Vistaar Finance will not only learn legal drafting but also get to understand the practical application of law in the financial sector. By the end of the internship, you can expect to develop:

  • Strong legal research and drafting skills
  • Practical knowledge of corporate and financial legal documentation
  • Understanding of compliance mechanisms in financial institutions
  • Ability to analyze contracts and agreements critically
  • Teamwork and professional communication skills
  • Hands-on experience in supporting an in-house legal team

Stipend and Benefits

  • Stipend: Paid internship (exact amount not specified, performance-based opportunities available)
  • Internship Certificate on successful completion
  • Opportunity to work with a leading financial institution
  • Practical exposure to corporate and financial legal work
  • Networking with professionals in finance and law

The paid nature of this internship ensures that students are rewarded for their contribution while also building skills that are highly relevant to the job market.

Why Choose Vistaar Finance for Your Legal Internship?

Unlike many internships that focus only on academic tasks, this position offers direct exposure to real-world corporate legal work. Interns will get the chance to see how legal principles are applied in everyday financial operations.

You will learn how contracts are drafted and reviewed for businesses, how compliance systems function, and how legal risk is managed in a financial institution. This makes it a valuable internship for those who wish to pursue careers in corporate law, banking, financial regulations, or in-house legal teams.

Application Process

If you are interested in applying for this internship, follow the steps below:

  1. Prepare your updated CV highlighting your academic background, legal skills, and relevant experiences.
  2. Draft a short and precise cover note expressing your interest in the legal internship at Vistaar Finance.
  3. Send your application to the email address given below.

How to Apply:
Send your CV and cover note to padmashree.m@vistaarfinance.com with the subject line:
“Application for Legal Internship – Vistaar Finance”

Final Thoughts

The Legal Internship at Vistaar Finance in Bangalore is an excellent opportunity for law students to gain paid, practical experience in the financial and corporate legal domain. It is particularly suitable for students who want to understand how law interacts with the finance sector and how corporate compliance operates in real time.

If you are ambitious, willing to learn, and want to kickstart your legal career with practical exposure, apply now and be a part of Vistaar Finance’s dynamic legal team.


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