Does time limit for completion of assessment stand extended if section 144C is followed?

Section 153 prescribes time limits for completion of assessment under the Act. On the other hand, sec 144C applies for transfer pricing cases. Under sec 144C, the AO, following the order of the transfer pricing officer, shall issue a draft order and afford the taxpayer 30 days time to make a reference before the Dispute Resolution Panel. The Panel has 9 months within which it has to give directions to the Assessing Officer who is then, within 30 days from the end of the month in which the directions of the Panel are received, issue the order of assessment.

Are all of these steps to be completed on or before the deadlines stipulated under sec 153? In the case of Shelf Drilling Ron Tappmeyer Limited, the Hon'ble Supreme Court delivered a split judgment. Due to this, the matter has been referred to the Hon'ble Chief justice of India to constitute a suitable Bench for taking up the matter.

For transfer pricing proceedings for FY 2022-23, this case is of particular importance because Transfer Pricing Orders will, likely, be issued soon and the time limit specified u/s 153 expires on 31^st March, 2026. But reference to DRP will likely not result in directions before that date. Taxpayers should carefully evaluate their strategy in such matters. Here, too, it is possible that a change in the law may be brought about in the forthcoming Union Budget.