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    <title>2026 (4) TMI 1471 - ITAT DELHI</title>
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    <description>The final assessment order was held time barred because it was passed after the one-month period prescribed under section 144C(13). The Dispute Resolution Panel&#039;s directions were received by the Assessing Officer on 30.12.2021, so the statutory deadline expired at the end of the next month; the order dated 31.07.2022 was far beyond that limit. The provision was treated as mandatory, with no discretion to extend time. The additional ground was admitted as it involved a pure question of law arising from the record, and the assessment order was set aside in favour of the assessee.</description>
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      <description>The final assessment order was held time barred because it was passed after the one-month period prescribed under section 144C(13). The Dispute Resolution Panel&#039;s directions were received by the Assessing Officer on 30.12.2021, so the statutory deadline expired at the end of the next month; the order dated 31.07.2022 was far beyond that limit. The provision was treated as mandatory, with no discretion to extend time. The additional ground was admitted as it involved a pure question of law arising from the record, and the assessment order was set aside in favour of the assessee.</description>
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