Dispute Resolution Panel objection deadlines extend to the next working day, barring final assessment before binding directions.
Section 10 of the General Clauses Act treats a Dispute Resolution Panel objection filed on the next working day as timely where the thirtieth day falls on a closed-office day, including Sunday. Section 144C requires the Dispute Resolution Panel to adjudicate a timely objection and issue directions before a final assessment is made. Those directions bind the assessing authority, and an assessment completed before the mandatory Dispute Resolution Panel process lacks jurisdictional foundation. The process must continue until merits adjudication and binding directions are issued.
Issues: (i) Whether an objection filed before the Dispute Resolution Panel on the next working day after the thirtieth day, which fell on a Sunday, was within the period under Section 144C(2) of the Income-tax Act, 1961; (ii) Whether a final assessment could be made without adjudication and directions of the Dispute Resolution Panel upon such timely objection.
Issue (i): Whether an objection filed before the Dispute Resolution Panel on the next working day after the thirtieth day, which fell on a Sunday, was within the period under Section 144C(2) of the Income-tax Act, 1961.
Analysis: Section 10 of the General Clauses Act, 1897 deems an act done on the next day on which the office is open to have been done in time where the last day of the prescribed period is a day on which the office is closed. Since the thirtieth day for filing the objection fell on a Sunday, the following working day was the valid last date.
Conclusion: The objection filed on 16 March 2026 was within limitation, and its rejection as time-barred was unsustainable, in favour of the assessee.
Issue (ii): Whether a final assessment could be made without adjudication and directions of the Dispute Resolution Panel upon such timely objection.
Analysis: The procedure under Section 144C of the Income-tax Act, 1961 is mandatory. Where a timely objection is filed, a final assessment may be made only after the Dispute Resolution Panel adjudicates the objection and issues directions under Section 144C(5); such directions are binding under Section 144C(10). A final assessment made before that process is completed lacks jurisdictional foundation.
Conclusion: The final assessment made without Dispute Resolution Panel adjudication and directions was without jurisdiction and was set aside, in favour of the assessee.
Final Conclusion: A timely objection before the Dispute Resolution Panel must be adjudicated on merits before a final assessment can lawfully be made, and the statutory Dispute Resolution Panel process is required to continue.
Ratio Decidendi: Where the last day for filing a Dispute Resolution Panel objection falls on a day when the office is closed, Section 10 of the General Clauses Act, 1897 permits filing on the next working day; a timely objection precludes final assessment until binding Dispute Resolution Panel directions are issued.