Non-speaking DRP directions under section 144C were set aside for failure to consider the assessee's objections properly.

Section 144C requires the Dispute Resolution Panel to consider the draft order, objections, evidence and reports before issuing binding directions, and a quasi-judicial authority must record cogent reasons consistent with natural justice. Where the Panel's directions are laconic and do not show proper consideration of the assessee's submissions, they are vitiated for want of a speaking order. The directions were set aside and the matter was remitted for fresh adjudication after granting an adequate opportunity of hearing.

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Issues: Whether the Dispute Resolution Panel's direction under section 144C, being laconic and non-speaking, was vitiated for consideration of the assessee's objections and required remand for fresh adjudication.

Analysis: Section 144C requires the Dispute Resolution Panel to consider the draft order, objections, evidence and reports before issuing directions binding on the Assessing Officer. A quasi-judicial authority dealing with disputed issues must give cogent reasons, and compliance with natural justice is essential. On the facts, the Panel's directions did not show proper consideration of the assessee's submissions and were found to be too laconic. Since the assessee's objections were brushed aside without adequate reasoning, the matter warranted restoration for fresh consideration.

Conclusion: The direction of the Dispute Resolution Panel was set aside and the matter was remitted for passing a proper and speaking direction after giving the assessee an adequate opportunity of hearing.

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