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HC held that the Assessing Officer was bound by section 144C(13) to complete the assessment within one month from the end of the month in which the DRP's directions under s.144C(5) were received, and had no discretionary power to extend or deviate from that mandate. The court rejected Revenue's contention that remand cases are exempt from the statutory timeline, treating the provision as mandatory and equally applicable on remand. Because the AO failed to give effect to the DRP directions within the prescribed period, any transfer-pricing addition sought thereafter cannot be sustained beyond the statutory timeline and the AO's action in completing the assessment late is impermissible.
HC held that the Assessing Officer was bound by section 144C(13) to complete the assessment within one month from the end of the month in which the DRP's directions under s.144C(5) were received, and had no discretionary power to extend or deviate from that mandate. The court rejected Revenue's contention that remand cases are exempt from the statutory timeline, treating the provision as mandatory and equally applicable on remand. Because the AO failed to give effect to the DRP directions within the prescribed period, any transfer-pricing addition sought thereafter cannot be sustained beyond the statutory timeline and the AO's action in completing the assessment late is impermissible.
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