Condonation of short delay in DRP objections turned on receipt date of draft assessment order and filing period computation.

A two-day delay in filing objections before the Dispute Resolution Panel under section 144C(2) was treated as condonable because the dispute depended on the date of receipt of the draft assessment order and the resulting thirty-day filing period. The objections were therefore directed to be entertained, and the matter was sent back to the DRP for decision on those objections. The separate contention on limitation in passing the final assessment order was not pressed.

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Issues: Whether the delay of two days in filing objections before the Dispute Resolution Panel under section 144C(2) of the Income-tax Act, 1961 was liable to be condoned and the objections treated as valid.

Analysis: The dispute turned on the date of receipt of the draft assessment order and the consequent computation of the thirty-day period for filing objections before the Dispute Resolution Panel. The record showed a short delay of two days in presenting the objections. In the circumstances, the delay was considered capable of being condoned, and the objections were directed to be entertained. The assessee did not press the separate contention regarding limitation in passing the final assessment order.

Conclusion: The delay in filing the objections was condoned and the matter was directed to go back to the Dispute Resolution Panel for decision on the objections; the appeal was allowed for statistical purposes.

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