Dispute Resolution Panel objections must be awaited before assessment is finalised; completed assessment and demand notice quashed.

Where an assessee filed objections before the Dispute Resolution Panel under section 144C(2) and also served them on the jurisdictional Assessing Officer, the assessment could not be completed before the Panel's directions under section 144C(5), even if the objections were not uploaded on the portal because of a technical impediment. The Bombay HC held that the Faceless Assessing Officer's assessment was unsustainable in these circumstances and quashed the assessment order as well as the consequential demand notice. The Assessing Officer was permitted to pass a fresh order after the Panel issues its directions.

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Issues: Whether the assessment order could be sustained when the assessee had filed objections before the Dispute Resolution Panel but the Faceless Assessing Officer proceeded to complete the assessment without awaiting the Panel's directions.

Analysis: The assessee had filed objections under section 144C(2) before the Dispute Resolution Panel and also furnished a copy to the jurisdictional Assessing Officer, though the objections were not uploaded on the portal due to a stated technical impediment. The assessment was completed without waiting for the directions contemplated under section 144C(5). In these circumstances, and following the earlier views referred to by the Court, the assessment order could not be sustained.

Conclusion: The assessment order was quashed and set aside, and the consequential notice of demand was also quashed and set aside. The Assessing Officer was left free to pass a fresh assessment order after the Dispute Resolution Panel issues its directions.

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