Faceless assessment notice must cover specific prejudicial variations; unexplained final additions without notice breach section 144B and natural just...
The case involves the validity of a final assessment order passed by the Assessing Officer (AO) u/s 144(C)(3) beyond the period of limitation. The Dispute Resolution Panel (DRP) plays a crucial role in deciding on objections raised by the assessee. The law mandates that the assessment order must be passed within one month from the end of the month in which the objections filing period expires. The DRP can confirm, reduce, or enhance the variations proposed in the draft order. In this case, the DRP rejected the objections as being time-barred, which effectively confirmed the draft order. However, this confirmation does not extend the limitation for passing the final order. As the DRP's directions were not communicated as required by law, the final order passed by the AO u/s 144C(13) was found to be without jurisdiction. Consequently, the appeals were allowed.
The case involves the validity of a final assessment order passed by the Assessing Officer (AO) u/s 144(C)(3) beyond the period of limitation. The Dispute Resolution Panel (DRP) plays a crucial role in deciding on objections raised by the assessee. The law mandates that the assessment order must be passed within one month from the end of the month in which the objections filing period expires. The DRP can confirm, reduce, or enhance the variations proposed in the draft order. In this case, the DRP rejected the objections as being time-barred, which effectively confirmed the draft order. However, this confirmation does not extend the limitation for passing the final order. As the DRP's directions were not communicated as required by law, the final order passed by the AO u/s 144C(13) was found to be without jurisdiction. Consequently, the appeals were allowed.
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