Mandatory DRP deadline under section 144C(13) makes a delayed final assessment order legally unsustainable and void.

The final assessment order under section 143(3) read with sections 144C(13) and 144B was treated as time-barred because the Assessing Officer failed to pass it within the mandatory one-month period counted from the end of the month in which the DRP directions were uploaded. The text states that the statutory deadline under section 144C(13) is mandatory, not directory, and that breach of that period renders the assessment order unsustainable in law. On that basis, the order was held void ab initio and quashed, and the consequential proceedings were said not to survive.

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Issues: Whether the final assessment order passed under section 143(3) read with section 144C(13) read with section 144B of the Income-tax Act, 1961 was barred by limitation and liable to be quashed.

Analysis: The directions of the DRP were uploaded on 30.09.2025, so the Assessing Officer was required under section 144C(13) to complete the assessment within one month from the end of that month, i.e. on or before 31.10.2025. The impugned final assessment order was passed only on 27.12.2025. The mandatory nature of the time limit under section 144C(13) was treated as settled by the binding jurisdictional precedent relied upon, which held that the statutory deadline is not directory and that breach of the prescribed period renders the assessment order unsustainable in law.

Conclusion: The assessment order was held to be barred by limitation, void ab initio, and quashed.

Final Conclusion: The appeal succeeded on the preliminary jurisdictional ground, and the assessment and all consequential proceedings did not survive.

Ratio Decidendi: The time limit prescribed in section 144C(13) for passing the final assessment order after receipt of DRP directions is mandatory, and an order passed beyond that period is invalid and liable to be quashed.

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