Validity of the final assessment order due to non-implementation...

Validity of the final assessment order due to non-implementation of the directions of learned DRP - Royalty/FTS receipts - The ITAT underscored the legal requirement u/s 144C(13) of the Income-tax Act, which obligates the AO to strictly adhere to the DRP's directions. Citing key judicial precedents, including the Bechtel Limited and ESPN Star Sports cases, the ITAT concluded that the AO's failure to implement the DRP's binding directions resulted in the final assessment order being declared void ab initio and without jurisdiction. Consequently, the Tribunal quashed the assessment order, thereby partly allowing the appeal in favor of the assessee.