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The Tribunal upheld the validity of the assessment order. Despite the alleged violation of statutory procedure u/s 144B, the Tribunal found that the assessment proceedings were not time-barred. The Dispute Resolution Panel's (DRP) directions u/s 144C(5) were initially not visible to the Assessing Officer due to a software issue. However, the Revenue proved that the DRP order was received by the National Faceless Assessment Centre on 06.04.2022 and uploaded on 18.04.2022, after which the Assessing Officer received it. The final assessment order passed on 30.05.2022 was within the time limit prescribed u/s 144C(13) from the date of receipt of the DRP order. Relying on the Supreme Court's interpretation of "receipt" in CIT vs. Mohammed Meeran Shahul Hameed, the Tribunal held the assessment order legally valid and decided against the assessee.
The Tribunal upheld the validity of the assessment order. Despite the alleged violation of statutory procedure u/s 144B, the Tribunal found that the assessment proceedings were not time-barred. The Dispute Resolution Panel's (DRP) directions u/s 144C(5) were initially not visible to the Assessing Officer due to a software issue. However, the Revenue proved that the DRP order was received by the National Faceless Assessment Centre on 06.04.2022 and uploaded on 18.04.2022, after which the Assessing Officer received it. The final assessment order passed on 30.05.2022 was within the time limit prescribed u/s 144C(13) from the date of receipt of the DRP order. Relying on the Supreme Court's interpretation of "receipt" in CIT vs. Mohammed Meeran Shahul Hameed, the Tribunal held the assessment order legally valid and decided against the assessee.
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