Limitation for final assessment under DRP directions runs from receipt by the Assessing Officer, making a delayed order invalid.

For section 144C(13) of the Income-tax Act, the limitation period for passing the final assessment order runs from the month in which the Dispute Resolution Panel directions are received by the Assessing Officer. On the stated facts, the directions were received on 30.05.2023, so the last permissible date was 30.06.2023. As the final assessment order was passed on 30.07.2023, it was beyond the statutory time limit and was treated as invalid, with the assessment set aside on limitation grounds.

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Issues: Whether the final assessment order passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 was barred by limitation on account of the date on which the Dispute Resolution Panel directions were received by the Assessing Officer.

Analysis: The email record and the technical report showed that the Dispute Resolution Panel directions were delivered to the Assessing Officer on 30.05.2023. Under section 144C(13), the final assessment order had to be passed within one month from the end of the month in which such directions were received. On that basis, the last permissible date was 30.06.2023. The order was passed on 30.07.2023, which was beyond the statutory limit.

Conclusion: The final assessment order was time barred and liable to be quashed.

Final Conclusion: The assessment order was set aside on the ground of limitation, and the appeal succeeded.

Ratio Decidendi: For purposes of section 144C(13) of the Income-tax Act, 1961, limitation runs from the month in which the Dispute Resolution Panel directions are received by the Assessing Officer, and any final assessment order passed beyond that period is invalid.

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