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HC held that the final assessment order passed by AO beyond the statutory time limit under Section 144C(13) was invalid. AO received DRP direction on 29.12.2015 and was mandated to complete assessment within one month from end of December 2015, i.e., by 31.01.2016. However, AO passed the assessment order on 18.02.2016, exceeding the prescribed timeline. The court ruled that Section 144C(13) provisions are mandatory, not discretionary, requiring AO to complete assessment within specified timeframe upon receiving DRP directions under Sub-Section (5). Since AO failed to comply with statutory timeline, the assessment order was deemed invalid. Appellant's appeal was allowed based on procedural non-compliance with mandatory statutory provisions.
HC held that the final assessment order passed by AO beyond the statutory time limit under Section 144C(13) was invalid. AO received DRP direction on 29.12.2015 and was mandated to complete assessment within one month from end of December 2015, i.e., by 31.01.2016. However, AO passed the assessment order on 18.02.2016, exceeding the prescribed timeline. The court ruled that Section 144C(13) provisions are mandatory, not discretionary, requiring AO to complete assessment within specified timeframe upon receiving DRP directions under Sub-Section (5). Since AO failed to comply with statutory timeline, the assessment order was deemed invalid. Appellant's appeal was allowed based on procedural non-compliance with mandatory statutory provisions.
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