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The Income Tax Appellate Tribunal (ITAT) held that the final assessment order passed by the Assessing Officer (AO) u/s 144C(4) read with Section 147 of the Income Tax Act was barred by limitation and void ab initio. The assessee had received the draft assessment order on 27.05.2023, and the due date for filing objections before the Dispute Resolution Panel (DRP) u/s 144C(2) was 26.06.2023. However, the assessee filed the objections on 06.07.2023, beyond the prescribed one-month time limit. Consequently, the AO was mandatorily required to pass the final assessment order by 31.07.2023. However, the AO passed the final order on 04.03.2024, well beyond the prescribed time limit. The ITAT held that by not adhering to the mandatory time limit, the final assessment order was barred by limitation and liable to be quashed.
The Income Tax Appellate Tribunal (ITAT) held that the final assessment order passed by the Assessing Officer (AO) u/s 144C(4) read with Section 147 of the Income Tax Act was barred by limitation and void ab initio. The assessee had received the draft assessment order on 27.05.2023, and the due date for filing objections before the Dispute Resolution Panel (DRP) u/s 144C(2) was 26.06.2023. However, the assessee filed the objections on 06.07.2023, beyond the prescribed one-month time limit. Consequently, the AO was mandatorily required to pass the final assessment order by 31.07.2023. However, the AO passed the final order on 04.03.2024, well beyond the prescribed time limit. The ITAT held that by not adhering to the mandatory time limit, the final assessment order was barred by limitation and liable to be quashed.
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