DRP directions under section 144C are binding; final assessment orders must conform to them or risk being quashed.

Section 144C requires the Assessing Officer to pass the final assessment order in conformity with the Dispute Resolution Panel's binding directions under section 144C(10), and within the time prescribed by section 144C(13). The text states that where the final order merely repeats the draft assessment order despite DRP relief and directions affecting transfer pricing computation, it does not comply with the statutory DRP procedure governing faceless assessment. On that basis, the final assessment order was treated as illegal and bad in law and quashed in favour of the assessee.

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Issues: Whether the final assessment order was liable to be quashed for having been passed without giving effect to the Dispute Resolution Panel's directions and contrary to the mandatory procedure under section 144C.

Analysis: The directions issued under section 144C(5) were binding on the Assessing Officer under section 144C(10), and the final order had to be passed in conformity with those directions within the time prescribed by section 144C(13). The order passed in the case was treated as a mere repetition of the draft assessment order, despite the DRP having granted relief and issued directions affecting the transfer pricing computation. On this basis, the order was held to be not in accordance with the statutory scheme governing the faceless assessment and DRP process.

Conclusion: The final assessment order was held illegal and bad in law and was quashed, in favour of the assessee.

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