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 DRPโ€™s 9-month period and AOโ€™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 DRPโ€™s 9-month period and AOโ€™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 Honโ€™ble Chief Justice of India for constituting an appropriate Bench to consider the issues afresh.

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Virtual Research Internship at Law Mantra Trust 2025: Apply by July 15

Virtual Research Internship at Law Mantra Trust 2025 is a valuable opportunity for aspiring legal professionals to engage in focused, research-driven work in the fields of Labour Law, Arbitration, and Mediation. Organized by the renowned Law Mantra Trust, this internship is designed for law students who are eager to build strong foundations in legal writing, policy analysis, and academic research.

Conducted in a virtual format, the internship provides flexibility for students across India to work remotely under the guidance of experts and contribute meaningfully to scholarly legal work. The program aims to cultivate critical thinking, encourage independent research, and refine academic writing skillsโ€”qualities essential for a successful legal career.

About Law Mantra Trust

Law Mantra Trust is a leading non-profit organization committed to advancing legal education, promoting research, and facilitating dialogue on legal reforms. The Trust regularly collaborates with legal scholars, practitioners, and institutions to publish research, conduct seminars, and offer training programs. The Virtual Research Internship at Law Mantra Trust 2025 reflects the organizationโ€™s dedication to nurturing young legal minds and fostering a culture of critical inquiry.

Over the years, Law Mantra has gained a strong reputation for delivering impactful legal insights through its internships and research programs. Interns who successfully complete these programs often go on to publish papers, participate in national-level debates, and join reputed law firms or pursue LLM programs.

About the Internship

The Virtual Research Internship at Law Mantra Trust 2025 is a month-long academic engagement focusing on three important legal domains:

  • Labour Law โ€“ Covering employment relations, worker rights, wage laws, and evolving industrial jurisprudence
  • Arbitration โ€“ Exploring domestic and international arbitration laws, procedural rules, and dispute resolution strategies
  • Mediation โ€“ Studying alternative dispute resolution frameworks with emphasis on non-adversarial dispute settlement methods

Interns will be tasked with legal research assignments, drafting briefs, preparing research notes, and potentially contributing to academic publications. The work will be conducted remotely, and guidance will be provided by mentors with expertise in the relevant legal fields.

Key Features:

  • Internship Type: Research-based and fully virtual
  • Duration: 1 Month
  • Eligibility: Law students (UG or PG)
  • Working Mode: Flexible remote work with periodic online check-ins
  • Certificate: Issued upon successful completion

Eligibility Criteria

The Virtual Research Internship at Law Mantra Trust 2025 is open to:

  • Students pursuing 5-year integrated or 3-year LLB programs
  • Postgraduate law students (LL.M.)
  • Individuals with an interest or academic background in Labour Law, Arbitration, or Mediation

Students with prior experience in legal writing, participation in moot courts or legal research competitions, or those seeking academic publication experience are encouraged to apply.

Application Process

Interested candidates must submit their applications by 15th July 2025.

Application Requirements:

Applicants must email the following documents to lawmantra001@gmail.com:

  1. Updated CV/Resume (clearly mentioning academic qualifications and any relevant experience)
  2. Brief Writing Sample โ€“ preferably on a topic related to Labour Law, Arbitration, or Mediation. The sample should be original and showcase the applicantโ€™s analytical and writing ability.

Selection Process:

  • Only shortlisted candidates will be contacted
  • Selections will be based on the quality of the writing sample, academic performance, and alignment with the subject areas

Benefits of the Internship

The Virtual Research Internship at Law Mantra Trust 2025 offers multiple benefits for budding legal professionals:

  • Research Skill Development โ€“ Interns will gain experience in academic writing, case analysis, and policy interpretation
  • Mentorship โ€“ Work under the guidance of legal experts, scholars, and practicing professionals
  • Flexible Structure โ€“ Participate from anywhere in India with manageable timelines and remote communication
  • Career Advancement โ€“ Enhances CV and prepares students for research-based roles, higher studies, and legal practice
  • Certification โ€“ Receive a certificate of completion that reflects your dedication and competence in research

Why This Internship Matters

In todayโ€™s legal ecosystem, being able to think critically, write precisely, and research effectively are non-negotiable skills. The Virtual Research Internship at Law Mantra Trust 2025 equips students with these capabilities. Whether you’re planning to pursue litigation, academia, or corporate law, the knowledge of alternative dispute resolution mechanisms and labour law gives you an edge.

Moreover, with legal reforms and labour code implementations ongoing in India, staying updated through this internship can be a practical advantage.

Important Dates

  • Last Date to Apply: 15th July 2025
  • Internship Start Date: Will be communicated to selected candidates

Contact Details

Email: lawmantra001@gmail.com

Conclusion

Donโ€™t miss out on the Virtual Research Internship at Law Mantra Trust 2025. Itโ€™s more than just a line on your resumeโ€”itโ€™s a step toward academic excellence and professional growth. Submit your application today and take your legal research journey to the next level.


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