Case of ACIT vs Shelf Drilling Ron Tappmeyer Ltd, SC Judgement Dated 8th August 2025. The apex court held that time consumed for concluding the proceeding under section 144C (Reference to dispute resolution panel) has to be subsumed within the limitation prescribed under section 153(3) (Time limit for completion of assessment, reassessment and re-computation) of the Income Tax Act. If orders are not made within time stipulated under section 153(3), then there would be no final assessment order and return as filed by the assessee would have to be accepted.