Typographical error in DRP direction could not sustain addition in final assessment; disputed sum deleted.

A typographical error in the DRP's deletion direction did not justify retaining an addition in the final assessment under section 144 read with section 144C(13). The assessment followed reopening under section 148 and notices under section 142(1), and the draft order had made an addition under section 69. On the substance of the DRP's direction, both proposed additions were covered for deletion, so no part of the disputed amount could validly survive in the final order. The article notes that the addition of Rs.10,00,000 was deleted and the matter was decided for the assessee.

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Issues: Whether the addition of Rs.10,00,000 could be sustained in the final assessment order when the Dispute Resolution Panel's direction to delete the additions was affected by a typographical error.

Analysis: The assessment was framed under section 144 read with section 144C(13) of the Income-tax Act, 1961 after reopening under section 148 and issuance of notices under section 142(1). The draft assessment had made an addition under section 69, and the Dispute Resolution Panel directed deletion of the additions in substance. The reference to Rs.3,28,25,770 instead of Rs.3,38,25,770 was held to be a typographical error, because the panel's direction effectively covered both components of the proposed addition. Once both additions were directed to be deleted, no amount could validly survive for retention.

Conclusion: The addition of Rs.10,00,000 was deleted and the issue was decided in favour of the assessee.

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