Binding DRP directions must be given effect in final assessment; an order passed in breach of that mandate is invalid.

Section 144C requires the Assessing Officer to complete the final assessment strictly in conformity with binding DRP directions, and a final order passed without giving effect to those directions is contrary to law. Where the assessment ignores the DRP's mandate and no rectification is made to cure the defect, the order remains invalid. The final assessment order was therefore quashed in favour of the assessee.

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Issues: Whether the final assessment order passed under section 144C(13) of the Income-tax Act, 1961, without giving effect to the DRP directions, was liable to be quashed.

Analysis: The statutory scheme under section 144C requires the Assessing Officer to complete the assessment in conformity with the directions of the Dispute Resolution Panel, and such directions are binding under section 144C(10). Where the final order is passed ignoring those binding directions and without incorporating the order giving effect to them, the assessment is not in accordance with law. The absence of a rectification step to cure the defect further reinforced that the assessment remained contrary to the mandatory procedure prescribed by the Act.

Conclusion: The final assessment order was invalid and was quashed, in favour of the assessee.

Ratio Decidendi: A final assessment order under section 144C(13) must be passed strictly in conformity with binding DRP directions, and an order made in breach of that mandate is liable to be quashed as contrary to law.

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