Belated DRP objection and unmet section 54F purchase conditions led to rejection of limitation challenge and exemption claim.

A belated objection under section 144C(2) could not invalidate the consequential final assessment, because the assessee failed to file DRP objections within the prescribed thirty-day period and could not rely on that delay to challenge limitation in the final order. The assessment therefore remained valid under the statutory scheme in sections 144C(4), 144C(5) and 144C(13). The claim for exemption under section 54F also failed, as the benefit depended on purchase of a qualifying residential house within the prescribed period, and the Tribunal found no basis to interfere with the denial of relief on the facts presented.

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Issues: (i) Whether the final assessment order was liable to be set aside as time-barred on the ground that the objection before the Dispute Resolution Panel was filed beyond the prescribed period and the consequential order was passed after the stipulated time. (ii) Whether the assessee was entitled to exemption under section 54F of the Income-tax Act, 1961 in respect of the capital gains arising from sale of the long-term capital asset.

Issue (i): Whether the final assessment order was liable to be set aside as time-barred on the ground that the objection before the Dispute Resolution Panel was filed beyond the prescribed period and the consequential order was passed after the stipulated time.

Analysis: Under section 144C(2) of the Income-tax Act, 1961, an eligible assessee must either accept the draft assessment order or file objections before the Dispute Resolution Panel within thirty days of receipt. The objection in the prescribed form was filed belatedly, and the Dispute Resolution Panel rejected it on the ground of delay. Once the objection was not filed within the statutory period, the assessee could not derive benefit from the delayed filing to challenge the subsequent final assessment on limitation grounds. The final order passed after the Dispute Resolution Panel directions was therefore treated as a valid consequence of the statutory scheme in sections 144C(4), 144C(5), and 144C(13).

Conclusion: The time-bar objection was rejected and the assessment was upheld.

Issue (ii): Whether the assessee was entitled to exemption under section 54F of the Income-tax Act, 1961 in respect of the capital gains arising from sale of the long-term capital asset.

Analysis: The claim under section 54F depended on purchase of a qualifying residential house within the prescribed period. On the facts considered, the assessee's reliance on the stated purchase date was not accepted for extending the exemption benefit. The Tribunal found no basis to interfere with the denial of exemption.

Conclusion: The claim for exemption under section 54F was rejected.

Final Conclusion: The appeal failed on both the limitation objection and the exemption claim, and the assessment as sustained by the Dispute Resolution Panel remained undisturbed.

Ratio Decidendi: A belated objection under section 144C(2) of the Income-tax Act, 1961 cannot be used to invalidate the consequential final assessment, and exemption under section 54F is available only upon satisfaction of the statutory purchase conditions within the prescribed period.

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