Mandatory DRP directions must shape the final assessment; a post-limitation corrigendum cannot cure the statutory defect.

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....Compliance with Dispute Resolution Panel directions under section 144C is mandatory when issuing the final assessment order. The text explains that where the Transfer Pricing Officer has given effect to those directions within the applicable limitation period, the Assessing Officer cannot issue a final order repeating the draft assessment position without incorporating them. A corrigendum issued after limitation cannot retrospectively cure that statutory defect or supply required findings, and is beyond jurisdiction. The described Tribunal decision therefore quashed the defective final assessment order, while leaving other grounds open.....