https://www.taxtmi.com/caselaws?id=445558 The HC held that an assessment order passed by FAO two years after DRP directions under Section 144C was time-barred and unsustainable. The court ruled that Section 144C is a self-contained provision with prescribed limitation periods that must be strictly followed. The department's claim that DRP directions were received late despite being uploaded on the portal earlier was rejected. The procedural failure constituted illegality vitiating the entire proceeding. Consequently, the return of income was accepted, and the petitioner was entitled to refund with interest within 30 days, without precluding revenue from reopening assessment through due process. en-us Wed, 08 Nov 2023 00:00:00 +0530 Wed, 13 Dec 2023 15:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445558 The HC held that an assessment order passed by FAO two years after DRP directions under Section 144C was time-barred and unsustainable. The court ruled that Section 144C is a self-contained provision with prescribed limitation periods that must be strictly followed. The department's claim that DRP directions were received late despite being uploaded on the portal earlier was rejected. The procedural failure constituted illegality vitiating the entire proceeding. Consequently, the return of income was accepted, and the petitioner was entitled to refund with interest within 30 days, without precluding revenue from reopening assessment through due process. Case-Laws Income Tax Wed, 08 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445558