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HC ruled that time limits under Section 144C(13) for completing assessments following DRP directions are mandatory, not directory. The AO must pass orders within one month from the end of the month in which DRP directions are received. This limitation period cannot be counted from when the Transfer Pricing Officer implements DRP directions. The assessment order dated February 27, 2015, was held time-barred as it exceeded statutory limits. The court emphasized that limitation laws provide certainty and finality to tax proceedings, preventing indefinite litigation exposure. Following precedent in Vodafone Idea Limited, the court affirmed the mandatory nature of Section 144C(13) timelines and ruled in the assessee's favor, stressing strict adherence to prescribed time limits.
HC ruled that time limits under Section 144C(13) for completing assessments following DRP directions are mandatory, not directory. The AO must pass orders within one month from the end of the month in which DRP directions are received. This limitation period cannot be counted from when the Transfer Pricing Officer implements DRP directions. The assessment order dated February 27, 2015, was held time-barred as it exceeded statutory limits. The court emphasized that limitation laws provide certainty and finality to tax proceedings, preventing indefinite litigation exposure. Following precedent in Vodafone Idea Limited, the court affirmed the mandatory nature of Section 144C(13) timelines and ruled in the assessee's favor, stressing strict adherence to prescribed time limits.
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