Mandatory time limit under section 144C(13) bars late final assessment orders, which were set aside as time barred.

The final assessment order was held time barred because it was passed after the one-month period prescribed under section 144C(13). The Dispute Resolution Panel's directions were received by the Assessing Officer on 30.12.2021, so the statutory deadline expired at the end of the next month; the order dated 31.07.2022 was far beyond that limit. The provision was treated as mandatory, with no discretion to extend time. The additional ground was admitted as it involved a pure question of law arising from the record, and the assessment order was set aside in favour of the assessee.

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Issues: Whether the final assessment order passed after the expiry of the period prescribed under section 144C(13) was time barred and liable to be quashed.

Analysis: The additional legal ground was admitted as it raised a pure question of law arising from the record. The directions of the Dispute Resolution Panel were received by the Assessing Officer on 30.12.2021, and under section 144C(13) the final assessment had to be completed within one month from the end of that month. The order dated 31.07.2022 was passed well beyond the statutory deadline. The provision was treated as mandatory, leaving no discretion to extend the period.

Conclusion: The final assessment order was held to be time barred and was set aside in favour of the assessee.

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