Binding DRP directions under section 144C must be followed strictly; substantive additions contrary to protective directions were void.

Directions issued by the Dispute Resolution Panel under section 144C are binding on the Assessing Officer, who must complete the final assessment strictly in conformity with them. Where the Panel required any assessed income to be treated on a protective basis, the Assessing Officer could not substitute substantive additions. Non-compliance with the directions rendered the final assessment orders without jurisdiction and void ab initio, and they were quashed.

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Issues: Whether the final assessment orders were liable to be quashed for failure to pass them in conformity with the binding directions of the Dispute Resolution Panel under section 144C.

Analysis: The assessment orders were passed after the Dispute Resolution Panel had directed that the income, if assessed, be treated on a protective basis. The Tribunal found that the Assessing Officer instead made substantive additions and did not implement the directions in letter and spirit. It held that once directions are issued under section 144C, they are binding on the Assessing Officer, who must complete the assessment strictly in conformity with them.

Conclusion: The final assessment orders were without jurisdiction and void ab initio for non-compliance with the binding directions under section 144C, and were quashed.

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