2021 (12) TMI 1415

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....l Demand Notice at Annexure - B dated 26.04.2021 issued by respondent No.1 / Assessing Officer as well as the impugned Order at Annexure - Q dated 24.11.2021 passed by respondent No.3 / Dispute Resolution Panel (for short, the 'DRP'). 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. The material on record indicates that pursuant to the Draft Assessment Order dated 16.02.2021 issued by the respondent No.1 / Assessing Officer to the petitioner, the petitioner filed objections under Section 144C(2)(b) of the Income Tax Act, 1961 (for short, the 'IT Act'), both before the respondent No.1 / Assessing Officer as well as before respondent No.3 / DRP wit....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....y following mandatory procedure under Section 144(C)5 to (C)13 of the IT Act. 5. Per contra, learned counsel for the respondents submits that there is no merit in the petition and the same is liable to be dismissed. 6. As rightly contended by the learned counsel for the petitioner, the material on record indicates that the year 2021 being a non-leap year comprising of only 28 days and the Draft Assessment Order having been issued on 16.02.2021, the petitioner had time upto a period of 30 days i.e., upto 18.03.2021 to file objections as required under Section 144C(2)(b) of the IT Act. It is an undisputed fact that the petitioner filed objections before both the DRP as well as the Assessing Officer on 16.03.2021 i.e., within the prescri....