Final assessment order deadline under DRP directions is mandatory; failure to comply renders the assessment time barred.

Dispute Resolution Panel directions under the income-tax scheme triggered the obligation to pass the final assessment order within one month from the end of the month in which the directions were received. Because no final assessment order was passed, either on the system or manually, even after the extended outer limit had expired, the assessment could not survive beyond the statutory time limit. The assessment was therefore held to be time barred and the impugned assessment proceedings were quashed.

---

---

Issues: Whether the assessment was barred by limitation for failure to pass the final assessment order within the time prescribed after receipt of the Dispute Resolution Panel directions under the income-tax scheme.

Analysis: The directions issued by the Dispute Resolution Panel under Section 144C(5) triggered the statutory obligation under Section 144C(13) to pass the final assessment order within one month from the end of the month in which such directions were received. The record showed that no such final order had been passed, either on the system or manually, even after the extended outer limit had expired. In these circumstances, the pending assessment could not survive beyond the statutory time limit.

Conclusion: The assessment was held to be time barred and the impugned assessment proceedings were quashed.

---