Reasonable-time requirement in DRP remand proceedings: inordinate delay made the directions and consequential assessment void.

Where remand proceedings before the DRP are not governed by an express statutory time-limit, the authority must still act within a reasonable period. A delay of more than 10.5 years in issuing directions was held far beyond any reasonable time, and the Tribunal treated the belated DRP directions and the consequential assessment order as barred by limitation and void ab initio. The Tribunal applied the principle that unexplained inordinate delay can defeat the validity of administrative or quasi-judicial action even when the statute is silent on timing, and granted relief to the assessee on that ground.

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Issues: Whether the directions issued by the DRP after an inordinate delay of more than 10.5 years, and the consequential assessment order, were barred by limitation and void in law.

Analysis: The Tribunal had earlier remanded the matter to the DRP for fresh consideration and a speaking order. In the remand proceedings, no specific statutory period was prescribed for disposal of the objections. The Tribunal held that, even where the statute is silent, the power must be exercised within a reasonable period. Referring to judicial principles that read a reasonable time-limit into proceedings where none is provided, the Tribunal found that a delay of more than 10.5 years was far beyond any reasonable period. The Tribunal therefore treated the belated DRP directions and the assessment order passed in consequence as suffering from fatal delay and limitation.

Conclusion: The DRP directions dated 08.09.2021 and the assessment order dated 30.09.2021 were held to be barred by limitation and void ab initio, and the assessee succeeded on this ground.

Ratio Decidendi: Where the statute does not prescribe a time-limit for completing remand proceedings, the authority must act within a reasonable period, and an inordinate unexplained delay can render the resulting directions and consequential assessment invalid as barred by limitation.

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