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ITAT, by reference to a third member, held that the DRP directions were effectively received by the AO on 13 April 2022 and, therefore, the one-month period under s.144C(13) expired on 31 May 2022. Consequently the final assessment order dated 30 June 2022 was beyond the statutory timeline, rendered without jurisdiction and liable to be quashed. The Tribunal directed cancellation of the impugned assessment order and allowed the assessee's challenge to limitation. A concurring judicial view and the third-member decision prevailed over the alternate administrative member's opinion that the AO had received DRP directions later and that the order was time-barred.
ITAT, by reference to a third member, held that the DRP directions were effectively received by the AO on 13 April 2022 and, therefore, the one-month period under s.144C(13) expired on 31 May 2022. Consequently the final assessment order dated 30 June 2022 was beyond the statutory timeline, rendered without jurisdiction and liable to be quashed. The Tribunal directed cancellation of the impugned assessment order and allowed the assessee's challenge to limitation. A concurring judicial view and the third-member decision prevailed over the alternate administrative member's opinion that the AO had received DRP directions later and that the order was time-barred.
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