Final assessment order issued under the relevant incometax...

Final assessment order issued under the relevant incometax provisions without incorporating Dispute Resolution Panel directions is invalid because the transfer pricing officer has not passed any order implementing those directions; therefore the assessing officer's final order is null and void. The Tribunal held that it cannot set aside the assessment to allow the TPO to pass a future order or extend time for that purpose; consequence: assessment quashed and decision in favour of the taxpayer. Prior precedents cited include decisions recognising the requirement to incorporate DRP directions before a valid final assessment is framed.

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