Section 144C compliance and clear DRP directions led to remand for implementable directions after noncompliance by the Assessing Officer.

Section 144C directions and the Assessing Officer's duty under section 144C(13) require clear, implementable compliance. Where the Assessing Officer substantially reiterates the draft assessment view instead of properly acting on the Dispute Resolution Panel's earlier directions, the resulting ambiguity can justify remand to enable effective implementation. On the facts noted, the directions were found insufficiently clear for execution, and the matter was remanded to the Dispute Resolution Panel to issue clearer directions and avoid further avoidable proceedings.

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Issues: Whether the assessment proceedings required remand to the Dispute Resolution Panel for clear and implementable directions where the Assessing Officer had not followed the earlier directions.

Analysis: The dispute centred on the effect of the Dispute Resolution Panel's directions under section 144C and the consequent obligation of the Assessing Officer under section 144C(13). The record showed that the Assessing Officer substantially reiterated the draft assessment view instead of acting on the directions in a clear and compliant manner. As the directions lacked sufficient clarity for implementation, continuing with the existing course would only prolong the controversy and lead to further avoidable proceedings.

Conclusion: The matter was remanded to the Dispute Resolution Panel to issue clear and implementable directions.

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