https://www.taxtmi.com/caselaws?id=314030 The ITAT Delhi held that assessment orders passed under section 144C were void-ab-initio due to the AO's failure to implement DRP directions. Despite reproducing DRP directions in the assessment orders, the AO merely copied the draft assessment order without implementing specific DRP guidance regarding treatment of service fees as FTS/FIS. The tribunal emphasized that non-implementation of DRP directions renders final assessment orders wholly without jurisdiction, following the precedent in ESPN Star Sports case. The assessment orders were consequently quashed, with the tribunal noting this represents a recurring problem requiring administrative attention. en-us Wed, 31 Jan 2024 00:00:00 +0530 Mon, 13 May 2024 21:32:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314030 The ITAT Delhi held that assessment orders passed under section 144C were void-ab-initio due to the AO's failure to implement DRP directions. Despite reproducing DRP directions in the assessment orders, the AO merely copied the draft assessment order without implementing specific DRP guidance regarding treatment of service fees as FTS/FIS. The tribunal emphasized that non-implementation of DRP directions renders final assessment orders wholly without jurisdiction, following the precedent in ESPN Star Sports case. The assessment orders were consequently quashed, with the tribunal noting this represents a recurring problem requiring administrative attention. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314030