Mandatory limitation for final assessment under section 144C(13) made the delayed order time-barred and unsustainable.

An assessment order passed under section 144C(13) must be completed in conformity with DRP directions within one month from the end of the month in which those directions are received. Where the final order is issued beyond that statutory period, the limitation breach renders the order time-barred and unsustainable. On the facts stated, the order passed on 22-02-2022 was beyond the prescribed timeline after receipt of DRP directions on 14-12-2021, so the assessment was quashed and the remaining grounds became academic.

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Issues: Whether the final assessment order passed under section 144C(13) of the Income-tax Act, 1961 was barred by limitation for having been issued beyond one month from the end of the month in which the DRP directions were received.

Analysis: The assessment was framed in pursuance of the DRP directions received on 14-12-2021. Under section 144C(13), the Assessing Officer was required to complete the assessment in conformity with those directions within one month from the end of the month of receipt. Since the final order was passed on 22-02-2022, it was beyond the statutory period. The mandatory nature of the timeline made the belated order unsustainable, and the other grounds became academic.

Conclusion: The final assessment order was held to be time-barred and liable to be quashed, in favour of the assessee.

Final Conclusion: The assessment was set aside on the ground of breach of the mandatory limitation under section 144C(13), and the appeal succeeded.

Ratio Decidendi: An assessment order under section 144C(13) must be passed within the prescribed one-month period from the end of the month in which the DRP directions are received, and non-compliance renders the order time-barred.

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