Limitation for final assessment orders under section 144C(13) runs strictly from receipt of DRP directions, making delayed orders void.

A final assessment order under section 144C(13) of the Income-tax Act must be passed within one month from the end of the month in which the Dispute Resolution Panel's directions are received by the Assessing Officer. On the facts stated, the directions were received on 22.09.2021, so the limitation expired on 31.10.2021, but the final order was passed only on 26.05.2022. Applying the binding precedent relied upon, the Tribunal treated the assessment as time-barred and held that it could not survive in law, quashing the order as void ab initio and deciding the issue in favour of the assessee.

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Issues: Whether the final assessment order was passed beyond the time limit prescribed under section 144C(13) of the Income-tax Act, 1961, and if so, whether the assessment was liable to be quashed.

Analysis: The final assessment order was required to be passed within one month from the end of the month in which the Dispute Resolution Panel's directions were received by the Assessing Officer. The record showed that the directions were intimated to the Assessing Officer on 22.09.2021, so the limitation expired on 31.10.2021. The final order, however, was passed on 26.05.2022, well beyond the prescribed period. Following the binding precedent relied upon, the Tribunal held that the assessment had become time-barred and could not survive in law.

Conclusion: The final assessment order was barred by limitation and was quashed as void ab initio. The issue was decided in favour of the assessee.

Ratio Decidendi: When the final assessment order under section 144C(13) of the Income-tax Act, 1961 is passed beyond the statutory time limit, the assessment is time-barred and liable to be quashed.

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