Supreme Court Split Verdict: A Taxation Tug-of-War
A Supreme Court bench delivered a split verdict on a tax case involving foreign drilling companies. The legal interpretation of Sections 144C and 153 of the Income Tax Act was contested, impacting the assessment timelines for non-residents. The matter will now proceed to the Chief Justice for further directions.

- Country:
- India
In a significant unresolved tax case, a Supreme Court bench handed down a split verdict regarding the appeal by the assistant commissioner of Income Tax against a 2023 Bombay High Court decision. This case implicates foreign drilling companies, prominently Shelf Drilling Ron Tappmeyer Ltd.
Justices B V Nagarathna and Satish Chandra Sharma diverged on interpreting Sections 144C and 153 of the Income Tax Act, 1961, which dictate assessment timelines for non-resident assessees. While Justice Nagarathna emphasized the time-barring nature of the proceedings, Justice Sharma advocated for a harmonious interpretation to ensure fair opportunity.
With conflicting judicial opinions, the case is now poised to be escalated to the Chief Justice of India for appropriate directives, potentially leading to deliberation by a larger bench, underscoring its significance in the realm of international taxation.
(With inputs from agencies.)