Limitation for final assessment after DRP directions led to quashing of the order as time-barred.

Final assessment order passed after receipt of Dispute Resolution Panel directions was held barred by limitation under section 144C(13) because the Assessing Officer was required to complete the assessment within one month from the end of the month in which the directions were received. As the directions were received on 23.12.2014, the statutory deadline expired on 31.01.2015, but the order was passed on 27.02.2015. The order was therefore treated as unsustainable in law and quashed in favour of the assessee.

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Issues: Whether the final assessment order passed after receipt of the Dispute Resolution Panel directions was barred by limitation under section 144C(13) of the Income-tax Act, 1961.

Analysis: The Tribunal found that the Assessing Officer received the Dispute Resolution Panel directions on 23.12.2014 and was required to complete the assessment within one month from the end of that month, i.e. by 31.01.2015. The final assessment order, however, was passed on 27.02.2015, beyond the statutory period prescribed under section 144C(13). As the order was made after the expiry of the mandated time limit, it was treated as unsustainable in law.

Conclusion: The assessment order was held to be barred by limitation and was quashed, in favour of the assessee.

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